BILLY J. WILLIAMS, OSB #901366 

United States Attorney 

District of Oregon 

ETHAN D. KNIGHT, OSB #99298 

GEOFFREY A. BARROW 

CRAIG J. GABRIEL, OSB #01257 

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 3:16-CR-00051-BR 

v. 

AMMON BUNDY, et al., 

· Defendants. 

State of Oregon ) 

) ss. 

County of Multnomah ) 

AFFIDAVIT OF KATHERINE D. 

ARMSTRONG IN SUPPORT OF 

MOTION FOR PROTECTIVE ORDER 

I, Katherine D. Armstrong, having been first duly sworn, do hereby depose and state as 

follows: 

1. I am a Special Agent (SA) of the Federal Bureau oflnvestigation (FBI) and have 

been so employed for approximately one-and-a-half (1 Yz) years. I am currently assigned to the 

violent and organized crime squad. In 2014, I successfully completed twenty-one (21) weeks of 

training at the FBI Academy located in Quantico, Virginia. During that time, I was taught the 

Case 3:16-cr-00051-BR Document 246 Filed 03/08/16 Page 1 of 6
use and practical application of various investigative techniques that Federal law enforcement 

officers are allowed to employ. In addition to my formalized training in violations of the law at 

the FBI Academy, I have also acquired knowledge and information pertaining to violations of 

federal law from numerous other sources, including: formal and informal training, other law 

enforcement officers and investigators, informants, and my participation in other investigations. 

Prior to joining the FBI, I was a prosecutor with the Philadelphia District Attorney's Office for 

approximately two-and-a-half years and briefly worked in the private sector as a civil litigator. I 

attended law school at Temple University in Philadelphia, Pennsylvania, and have been certified 

to practice law since October 2010. 

2. This affidavit is submitted in support of the government's Motion for a Protective 

Order under Federal Rule of Criminal Procedure 16( d)(1 ). 

3. I am one of the Special Agents assigned to the investigation of the defendants in 

United States v. Ammon Bundy, et al., Case No. 3:16-CR-00051-BR; and United States v. Blaine 

Cooper, et al., Case No. 3:16-CR-00064-JO. I am familiar with the facts related to the charge 

against defendants of Conspiracy to Impede Officers of the United States under 18 U.S.C. § 372. 

I am further familiar with much of the discovery in the investigation, including written reports of 

witness interviews. 

4. The facts set forth in this affidavit are based on my own personal knowledge; 

knowledge obtained from other individuals during my participation in this investigation, 

including other law enforcement officers; interviews of witnesses; my review of records related 

to this investigation; and communications with others who have knowledge of the events and 

circumstances described herein. 

Affidavit of Katherine D. Armstrong in Support of Motion for 

Protective Order Pertaining to Discovery 

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5. My experience with the investigation in these cases, and my review of the 

discovery, have shown that numerous witnesses in the Bundy and Cooper cases were harassed, 

threatened, or intimidated by the defendants, persons associated with the defendants, so-called 

militia members, or persons sympathetic to the defendants. My review of the discovery to date 

causes me to believe that if witness statements provided to the defense in discovery were to be 

publicly disseminated, then it would be highly likely that those witnesses would be subject to 

harassment, threats, and intimidation. A few examples of previous witness harassment and 

intimidation are provided below: 

a. On December 18, 2015, a citizen (hereafter Citizen) of Harney County, 

was shopping at the Safeway grocery store in Bums, Oregon. Citizen was wearing a 

BLM shirt. Citizen was confronted by two men, whom the Citizen has since identified as 

defendants in the above cases. Citizen reported to law enforcement that she heard 

yelling, and when she turned around, a defendant shouted "you're BLM, you're BLM" at 

her. One of the defendants further stated to Citizen that they know what car she drives 

and would follow her home. One of the defendants told the Citizen that he was going to 

bum Citizen's house down. The two defendants then left the area in a black pickup truck 

with black canopy and no visible license plate. Since the incident, Citizen has observed a 

similar vehicle outside her residence. Citizen was unable to identify the driver of the 

vehicle when she later saw it. The following week, a second vehicle, described as a 

white truck with a pink license plate and a big rebel flag sticker on: the back window, 

aggressively tailgated Citizen, flashing lights and driving erratically. Citizen believed the 

Ill 

Affidavit of Katherine D. Armstrong in Support of Motion for 

Protective Order Pertaining to Discovery 

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second incident was related to the first. Citizen also saw the black pickup truck outside 

of her place of employment early in the morning hours of Christmas Day. 

b. On December 13, 2015, a Harney County law enforcement official 

received an email that read in part, "Have a good read you two bit punk ... What you 

gonna do when they come for YOU??? By the thousands .. PUNK. You no doubt come 

from a family of liars and punks .... " On December 16, 2015, the parents of this Harney 

County law enforcement official described being followed after leaving a school play. 

On a separate occasion, around January 1, 2016, one of the parents described seeing a 

black, Ford pickup truck with two men in the passenger compartment, with Colorado 

license plates and a long gun in a rack in the cab, watching him when he exited his house 

to pick up his mail. The parents described feeling harassed on these occasions. 

c. The minor child of a nearby town's police chief was followed home 

sometime between December 25, 2015, and January 2, 2016. The minor was followed by 

a midsized, white pickup truck for 25-30 minutes. On January 1, 2016, the minor was 

again followed while driving. This time, the minor was followed by a red, Dodge pickup 

truck. The truck followed the minor from the minor's home for approximately ten 

minutes. 

d. For approximately ten days starting around January 16, 2016, an 

environmentalist traveled to the Malheur National Wildlife Refuge (MNWR) every day 

and held press conferences after the armed occupiers had given their own press 

conference. The environmentalist stated his life was threatened twice during that time 

period. A second environmentalist was accused by a defendant of being an undercover 

Affidavit of Katherine D. Armstrong in Support of Motion for 

Protective Order Pertaining to Discovery 

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FBI agent. Both environmentalists left the MNWR after the accusation, as the crowd 

"became very ugly" according to an interview with one of the environmentalists. 

e. Multiple social media postings collected by the FBI show defendants, 

persons associated with the defendants, so-called militia members, and others 

sympathetic to defendants making threatening, intimidating, and harassing statements 

regarding federal agency employees. 

6. Based on my training, experience in this case and others, and conversations with 

other law enforcement officials, I believe that if the names of these federal agency employees 

were to be made publicly available, then these witnesses would almost certainly be subject to 

threats, intimidation, and harassment while this case is pending trial. 

7. Based on my training, experience in this case and others, and conversations with 

other law enforcement officials, I believe that if the names of witnesses who have provided 

statements to law enforcement were to be made publicly available, then these witnesses would 

almost certainly be subject to threats, intimidation, and harassment while this case is pending 

trial. 

8. Finally, the government has obtained sensitive materials in this investigation from 

search warrants and court orders. The materials obtained contain private information regarding 

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Affidavit of Katherine D. Armstrong in Support of Motion for 

Protective Order Pertaining to Discovery 

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the defendants and third parties. I believe that public dissemination of this material would 

implicate witnesses' privacy interests and subject them to threats, intimidation, and harassment. 

~k£0.~~ ~rine D. ArmstrOlli~~ 

Special Agent 

FBI Portland Division 

Subscribed and sworn to before me this --=---day ofMarch 2016. 

~~·~ Not y Publi, for State of Oregon 

My Commission Expires: 0 e;t. -l J ~0 I 

Affidavit of Katherine D. Armstrong in Support of Motion for 

Protective Order Pertaining to Discovery 

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