BILLY J. WILLIAMS, OSB #901366 

United States Attorney 

District of Oregon 

ETHAN D. KNIGHT, OSB #992984 

GEOFFREY A. BARROW 

CRAIG J. GABRIEL, OSB #012571 

Assistant United States Attorneys 

ethan.knight@usdoj.gov

geoffrey.barrow@usdoj.gov 

craig.gabriel@usdoj.gov

1000 SW Third Ave., Suite 600 

Portland, OR 97204-2902 

Telephone: (503) 727-1000 

Attorneys for United States of America 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

UNITED STATES OF AMERICA 

 v. 

AMMON BUNDY, et al. 

 Defendants.

3:16-CR-00051-BR

JOINT STATUS REPORT 

REGARDING DISCOVERY

 Pursuant to the Court’s April 11, 2016, Order (ECF No. 389), attorneys for the government 

have conferred with the Defendants’ Discovery Committee. After conferral, the parties offer the 

following joint statement: 

 To date, the government has produced six volumes of discovery that comprise 14,079 

Bates pages, 48,050 files, and 94 gigabytes of data. For defendants’ convenience, the 

government has produced discovery in multiple formats including .pdf, text files, tiffs, load files, 

and natives. 

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Joint Status Report Regarding Discovery Page 2

 Volumes 1 and 2 were sent directly to counsel. Pursuant to the Court’s discovery 

management order, Volumes 3 through 6 were originally provided to CJA Counsel Jennifer 

Horvath for distribution to all defense counsel. Ms. Shertz, Mr. Rainwater, and Ms. Wood report 

that distribution by the CJA Panel office has thus far been limited to portions of Volume 3 that 

included only the PDFs, no native files, and no further distribution of Volumes 4-6. The rest of 

Volumes 3-6 remain at the Panel office awaiting the cloud solution. 

 Following the April 6, 2016, Status Hearing, government counsel conferred with defense 

counsel interested in receiving individual copies of discovery, including counsel for Jon 

Ritzheimer, Terri Wood; counsel for James Blomgren, Robert Rainwater; and counsel for Daryl 

Thorn, Laurie Shertz. The above parties agreed to the following: The government procured 

equipment to reproduce certain hard drives. The above attorneys have procured hard drives that 

are compatible with the government’s equipment. The government has made Volumes 3 through 

6 available to the above attorneys and will produce future volumes to the above defense counsel on 

the defense-provided hard drives. 

 Advisory counsel for Ryan Bundy has advised him of the government’s proposal, but 

Mr. Bundy has not made a decision on this issue. 

 The government is currently processing the next batch of discovery. The next production 

will include law enforcement reports and photographs. The government estimates that this 

production will be more than 150 GB and will be available Monday, April 18. 

 The government has also conferred with Tom Coan, counsel for Pete Santilli, and provided 

estimates about the volume and nature of future discovery productions in order to help the defense 

obtain a contractor to facilitate discovery hosting by a third-party vendor. The government 

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Joint Status Report Regarding Discovery Page 3

believes that video will be the most data-intensive materials and that defense-produced video, i.e., 

social media, would likely exceed the volume of video materials produced by the government. 

The government will also be producing a significant amount of computer forensics reports. This 

information was provided to help the defense in working with a third-party vendor. 

 The parties will continue to work together to resolve discovery production issues. 

 Dated this 13th day of April 2016. 

 Respectfully submitted, 

 BILLY J. WILLIAMS 

 United States Attorney 

 s/ Geoffrey A. Barrow 

 ETHAN D. KNIGHT, OSB #992984 

 GEOFFREY A. BARROW 

 CRAIG J. GABRIEL, OSB #012571 

 Assistant United States Attorneys 

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