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JOHN S. LEONARDO

United States Attorney

District of Arizona

LISA E. JENNIS

Assistant U.S. Attorney

Two Renaissance Square

40 N. Central Ave., Suite 1200

Phoenix, Arizona 85004

Telephone: 602-514-7500

Email: lisa.jennis@usdoj.gov

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

United States of America,

Plaintiff, 

vs. 

Jon Ritzheimer,

Defendant.

Case No. 16-6019MJ

AMENDED

UNITED STATES’ MEMORANDUM IN 

SUPPORT OF PRETRIAL DETENTION

INTRODUCTION AND SUMMARY OF ARGUMENT

The United States of America, by and through undersigned counsel, hereby files 

this memorandum in support of pretrial detention of defendant Jon RITZHEIMER. For 

the reasons set forth below and based on the information that will be presented at the 

February 2, 2016, detention hearing, this Court should order that defendant 

RITZHEIMER be detained pending trial.

On January 26, 2016, defendant was charged by complaint out of the District of 

Oregon along with seven co-conspirators, with conspiring to impede officers of the 

United States from discharging their official duties through the use of force, intimidation, 

or threats, in violation of Title 18, United States Code, Section 372. See Complaint Case 

Number 16-MJ-00004, United States District Court, District of Oregon. Another 

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complaint was filed the next day against an additional three co-conspirators for the same 

conduct. See Complaint Case Number 16-MJ-00006, United States District Court, 

District of Oregon. The circumstances of this crime, standing alone, compel the 

conclusion that RITZHEIMER is a grave danger to the community and a flight risk. The 

underlying facts of this conspiracy pose unique issues that weigh in favor of detention 

and by its very nature, this offense demonstrates a remarkable inability on the part of 

defendant and his co-conspirators to follow the law, and thus comply with the terms of

court-ordered supervision. In this case, the defendant and his co-conspirators deliberately 

and publicly disregarded repeated orders, requests, and pressure to obey the law over a 

sustained period of time. They did so in manner that endangered, and continues to 

endanger, the residents of Harney County, Oregon and law enforcement. Critically, the 

alleged crime was not born out of impulse—it was deliberate and designed to undermine 

authority at every stage. As a result, the defendant appears before this Court having 

already demonstrated that no condition or combination of conditions could reasonably 

assure his appearance or the safety of the community.

At the hearing, the United States will rely on a proffer (contained below) detailing 

the conspiracy, and on the history and characteristics of defendant RITZHEIMER. United 

States v. Winsor, 785 F.2d 755, 756 (9th Cir. 1986) (“[T]he government may proceed in a 

detention hearing by proffer or hearsay.”). The United States also may present testimony 

at the hearing, if the Court wishes to hear testimony from a Special Agent with the 

Federal Bureau of Investigation (FBI).

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FACTUAL AND PROCEDURAL HISTORY

Defendant RITZHEIMER’s ten co-conspirators Ammon Bundy, Joseph 

O’Shaughnessy, Ryan Payne, Ryan Bundy, Brian Cavalier, Shawna Cox, Peter Santilli, 

Jason Patrick, Duane Leo Ehmer and Dylan Anderson were arrested on January 26 and 

27, 2016, in the District of Oregon. RITZHEIMER traveled to Oregon in December 

2015 to participate in the protest rally in Burns, Oregon in support of two ranchers, 

Dwight and Steven Hammond, who were convicted of federal arson. Following the 

protest, on January 2, 2016, RITZHEIMER along with many of his co-conspirators, 

unlawfully entered and occupied the locked buildings and grounds of Malheur National 

Wildlife Preserve (MNWP). RITZHEIMER, along with the other individuals, tactically 

cleared the grounds and buildings while carrying loaded rifles. RITZHEIMER remained 

in Oregon until January 25, 2016, when he left to visit his family in Peoria, AZ. After the 

arrests of his co-defendants on January 26, 2016, and the death of Robert LaVoi Finicum, 

who was killed during his efforts to avoid apprehension, RITZHEIMER was contacted by 

the FBI and requested that he self-surrender. After a couple of hours and numerous 

telephone calls, the FBI successfully negotiated with RITZHEIMER to turn himself in at 

the Peoria Police Department.

On January 29, 2016, detention hearings were for held for defendant’s coconspirators in the District of Oregon before the Honorable Judge Stacie F. Beckerman

who detained: Ammon Bundy, Ryan Bundy, Ryan Payne, Peter Santilli, Jason Patrick 

and Dylan Anderson. Joseph O’Shaughnessy’s order of release was appealed by the 

government and it will be heard by a U.S. District Court Judge on February 2, 2016. The 

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parties agreed to release Shawna Cox pending conclusion of the occupation which was 

later amended to allow for release on February 1, 2016. Due to recently appointed 

counsel, Brian Cavalier and Duane Leo Ehmer’s detention hearings are currently set for

February 4, 2016.

SUMMARY OF FACTS CONTAINED IN THE COMPLAINT

The 31 page complaint charges defendant with Conspiracy to Impede Officers of 

the United States from discharging their official duties though the use of force, 

intimidation and threats. The facts of which are summarized below:

On January 2, 2016, and continuing through January 26, 2016, the co-conspirators 

and others conspired to impede by force, intimidation, or threat, officers of the United 

States from discharging their duties in the Malheur National Wildlife Refuge (MNWR) in 

Harney County, Oregon, in violation of Title 18, United States Code, Section 372. The 

co-conspirators conducted an armed occupation of the MNWR, a unit of the National 

Wildlife Refuge System which is federal property managed by the United States Fish and 

Wildlife Service (USFWS). 

On June 6, 2012, Dwight and Steven Hammond were convicted of two counts of 

arson by a jury in the District of Oregon. They were originally sentenced on October 30, 

2012. Dwight Hammond was sentenced to serve three months in prison, and Steven 

Hammond was sentenced to serve twelve months. On February 7, 2014, the Ninth 

Circuit Court of Appeals overturned the District Court’s sentence. On October 7, 2015, 

Dwight and Steven Hammond were resentenced to serve a mandatory, five-year term of 

imprisonment. On January 4, 2016, the Hammonds reported to a Federal Correctional 

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Institute in California to serve the remainder of their sentences. Prior to surrendering to 

serve their sentences, the Hammonds, through their attorney, continued to distance 

themselves from the would-be occupiers.

On January 4, 2016, co-defendant Ammon Bundy addressed the media and stated 

that he named his group of protesters the “Citizens for Constitutional Freedom” (CCF), 

and they were acting in support of the Hammonds. Bundy told a national morning news 

show that members of CCF were armed because “[w]e are serious about being here. 

We’re serious about defending our rights, and we are serious about getting some things 

straightened out.” When asked if he anticipated it would lead to violence, Bundy

responded, “Only if the government wants to take it there.”

In a video posted on an Internet website titled “Citizens for Constitutional 

Freedom News Conference” posted on January 4, 2016, Bundy said their purpose is to 

restore and defend the Constitution, and they have spent two months petitioning the state 

and county representatives to stand for the Hammonds against the so-called 

“unconstitutional actions.” Bundy said, “We feel that we have exhausted all prudent 

measures and have been ignored. And it has been left to us to decide whether we allow 

these things to go on or whether we make a stand.” On January 4, 2016, Harney County 

Sheriff Dave Ward held a press conference and informed the armed occupiers of the 

MNWR that the Hammonds had peacefully surrendered themselves to complete their 

federal sentences and informed the armed occupiers that “it was time to leave.”

On October 5, 2015, prior to the occupation of MNWR, Bundy visited Harney 

County Sheriff Dave Ward in Harney County. During the visit, Bundy and Ryan Payne 

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told Sheriff Ward that he needed to protect the Hammonds from going back to prison. 

Payne and Bundy informed Sheriff Ward that if the Hammonds spent one more day in 

jail there would be “extreme civil unrest.” On November 12, 2015, Bundy publicly 

posted a letter from the Bundy family to Harney County Sheriff Dave Ward. The letter 

was posted online at http://bundyranch.blogspot.com (Attachment 1) and was still 

publicly viewable as of January 4, 2016. In summary, the Bundy family claims that 

federal employees are abusing their positions within the federal government to punish the 

Hammond family. Several additional blog posts, made on November 12, 2015, and later, 

further stated that it was the Bundy family’s position that the Hammond family had been 

illegally arrested.

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

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

shirt. Citizen was confronted by two men, one whom she identified as defendant 

RITZHEIMER. Citizen reported to law enforcement that she heard yelling, and when 

she turned around, the second individual shouted “you’re BLM, you’re BLM” at her. 

That person further stated to Citizen that they know what car she drives and would follow 

her home. The second individual also stated he was going to burn Citizen’s house down. 

RITZHEIMER and the second individual left the area in a black pick-up 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. 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, 

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flashing lights and driving erratically. Citizen also saw the black pick-up truck outside of 

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

On December 26, 2015, a video posted to an Internet website channel indicated 

the video is a “call out” to all “patriots” to meet at the Safeway parking lot in Burns, 

Oregon, on January 2, 2016, for the protest. A screenshot from the video, attached 

below, shows RITZHEIMER on the far right. In the video each individual identifies 

himself by name. https://www.youtube.com/watch?v=kGuizh7evHc (Attachment 2)

On December 31, 2015, a video posted to an Internet website showed 

RITZHEIMER in a car saying “we the people need to take a stand,” “we need real men 

and women here to take a stand” and that he has “had to do a lot of soul searching” and 

he is “one hundred percent willing to lay down my life, to fight against tyranny in this 

country.” https://www.youtube.com/watch?v=sbGdMKpHDDE (Attachment 3)

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On January 2, 2016, several hundred unidentified individuals participated in a 

protest in Burns, Oregon, related to the resentencing of Steven and Dwight Hammond. 

Following the protest, A. Bundy, RITZHEIMER, Payne, R. Bundy, Cavalier, and 

Finicum, among others, entered the Malheur National Wildlife Refuge, blocked the 

entrance to the Refuge, and began their armed occupation of several buildings within the 

MNWR. The MNWR and all buildings located thereon are federal property and 

facilities. The armed occupation of the MNWR has been continuous and ongoing since 

January 2, 2016. The MNWR is located in Harney County, District of Oregon. 

The MNWR is staffed by employees of the United States Fish and Wildlife 

Services. As a result of the armed occupation of the MNWR by the defendants and 

others, which began on or about January 2, 2016, and continuing to the present, 

employees of the USFWS who work at the MNWR have been prevented from reporting 

to work because of threats of violence posed by the defendants and others occupying the 

property. According to a Special Agent with the Bureau of Land Management (BLM), 

on January 2, 2016, the BLM learned, by watching a live online video stream, that 

numerous individuals including RITZHEIMER left the rally that was in support of the 

Hammonds in Burns, Oregon, and travelled to the Malheur National Wildlife Refuge to 

take it over. BLM was notified later that day by a Harney County Sheriff’s Officer that a 

source informed him that the group controlled the Refuge and had explosives, night 

vision goggles, and weapons and that if they didn’t get the fight they wanted out there 

they would bring the fight to town.

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Due to the presence of armed individuals occupying the Refuge and also learning 

that some of their associates were still in the Burns area, the BLM made the decision to 

close the Burns District Office, located at 28910 Highway 20 West, Hines, Oregon, 

97738, for the upcoming work week. This BLM action was taken out of concern for the 

safety of the approximate 80 employees who work there.

On January 3, 2016, a video posted on an Internet website by “The Conspiracy 

Scope” showed A. Bundy and two others at the MNWR. The location of this video at the 

MNWR was confirmed by a Federal Wildlife Officer of the U.S. Fish and Wildlife 

Service. The Federal Wildlife Officer confirmed that they were at the main entrance to 

the MNWR. One individual was in the background holding a rifle. A. Bundy stated that 

we have “taken over the Malheur National Wildlife Refuge” and that the MNWR will 

become a “base place for patriots from all over the country to come and be housed.” A. 

Bundy continues by saying that “we’re planning on staying here for several years.” A. 

Bundy also says in the same video, “We are calling people to come out here and stand” 

and “We need you to bring your arms and we need you to come to the Malheur National 

Wildlife Refuge.” One individual is also in the video saying that he agreed with A. 

Bundy and that they need people to “bring your arms.”

https://www.youtube.com/watch?v=Hb9cRoHWlVg (Attachment 4)

RITZHEIMER appeared in a video titled “Militants take to social media to recruit 

supporters,” posted on January 4, 2016, to an Internet website and stated, “We are in my 

truck parked outside the Refuge,” “We need you to get here and stand with us,” “whether 

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you are armed or unarmed,” and “Please get up here to help us.” Another person also 

appeared in the video stating, “We need your help guys.”

https://www.youtube.com/watch?v=qeqhtTMp9dc (Attachment 5) RITZHEIMER also 

posted a video where he stated, “I’ve had to do a lot of soul searching up here, and I am 

with good people who also have had to do a lot of soul searching, some who’ve done this 

soul searching for years, and I am one hundred percent willing to lay my life down, to 

fight against tyranny in this country.”

https://www.youtube.com/watch?v=sbGdMKpHDDE (Attachment 3)

A photo posted on an Internet news website shows RITZHEIMER adjusting a sign 

outside the MNWR on January 5, 2016, shown below. A Federal Wildlife Officer with 

the U.S. Fish and Wildlife Service has confirmed the location of the signs on the MNWR 

close to the main entrance. 

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On January 5, 2016, in a video posted to an Internet website, 

https://www.youtube.com/watch?v=n6BYPzFM_r0 (Attachment 6) RITZHEIMER stated

“last word we got is they’re headed out here” in reference to the belief by armed 

occupiers that they were going to be raided by the federal government. RITZHEIMER

further stated, “We got word that they’re coming out here, uh so we are trying to plan and 

maintain a defensive posture” and “Right now underneath that tarp right there—Lavoi

Finicum is sitting underneath that tarp, and he is not going to let them come through. 

We’re maintaining a defensive posture back here.” In the still shot below, 

RITZHEIMER is carrying what appears to be an AR-15-style rifle with a sling. In the 

following two still shots are additional photographs of RITZHEIMER conducting an 

armed patrol at the MNWR.

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http://photos.oregonlive.com/4450/gallery/oregon_militia_standoff_near_b_1/index.html#/82

Oregon militia standoff

A member of the group occupying the Malheur National Wildlife Refuge headquarters stands guard Tuesday, 

Jan. 5, 2016, near Burns, Ore. Ammon Bundy, the leader of a small, armed group that is occupying a remote 

national wildlife preserve in Oregon said Tuesday that they will go home when a plan is in place to turn over 

management of federal lands to locals. (AP photo/Rick Bowmer)

Beth Nakamura | The Oregonian/OregonLive

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http://photos.oregonlive.com/4450/gallery/oregon_militia_standoff_near_b_1/index.html#/92

Oregon militia standoff

A member of the group occupying the Malheur National Wildlife Refuge headquarters stands guard Tuesday, 

Jan. 5, 2016, near Burns, Ore. Ammon Bundy, the leader of a small, armed group that is occupying a remote 

national wildlife preserve in Oregon said Tuesday that they will go home when a plan is in place to turn over 

management of federal lands to locals. (AP photo/Rick Bowmer)

Beth Nakamura | The Oregonian/OregonLive

A video entitled “#aslongasittakes” was live-streamed starting January 5, 2016, 

continuing into January 6, 2016, and posted to an Internet website channel. 

https://www.youtube.com/watch?v=n6BYPzFM_r0 (Attachment 6) The video is filmed 

at or just outside the MNWR. The location of the video outside the MNWR was 

confirmed by a Federal Wildlife Officer. In the video, an armed occupier was 

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interviewed and stated, “We have people here that are standing up for the constitution,” 

“We need every patriot in this country to come out here and and support the message,” 

“You guys need to be out here to show your support you need to stop the bickering,” and 

“If you want to lock arms in front of this reserve and make sure that these federal agents 

and this corrupt government doesn’t come through those gates, you can do that. Or if you 

want to go on in and do what you gotta do then go on and do that, everybody has a place 

in this and everybody need to be here.” The person further stated in the interview, “I’m 

right now in the process of trying to set up a constitutional security protection force to 

make sure that these federal agents and these law enforcement don’t just come in here 

like cowboys, that’s we have to prevent that um.”

ARGUMENT

Under the Bail Reform Act, a judicial officer shall detain a defendant pending trial 

if “no condition or combination of conditions will reasonably assure the appearance of 

the person as required and the safety of any other person and the community.” 18 U.S.C. 

§ 3142(e). Detention is appropriate where a defendant is either a flight risk or a danger to 

the community and it is not necessary to prove both. See United States v. Motamedi, 767 

F.2d 1403, 1406 (9th Cir.1985); United States v. Kouyoumdijan, 601 F. Supp. 1506, 

1508-10 (C.D. Cal 1985). A finding that a defendant is a danger to the community must 

be supported by clear and convincing evidence. A finding that a defendant is a flight risk 

need only be supported by a preponderance of the evidence. See Motamedi, 767 F.2d at 

1406.

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In determining whether pretrial detention is appropriate, the court should consider 

four factors under18 U.S.C. § 3142(g): (1) the nature and circumstances of the offense 

charged; (2) the weight of the evidence against defendant; (3) the history and 

characteristics of the defendant; and, (4) the nature and seriousness of the danger posed 

by defendant’s release. United States v. Townsend, 897 F.2d 989, 994 (9th Cir. 1990); 18 

U.S.C. § 3142(g).

A. Statutory Factors Requiring Detention

Title 18, United States Code, Section 3142(g) sets forth factors for the court to 

consider in determining whether there are conditions of release that will reasonably 

assure the appearance of the person as required and the safety of any other person and the 

community. The following factors apply to defendant RITZHEIMER:

1. Nature and Circumstances of the Offense

The charged offense involves the ongoing armed occupation of the Malheur 

National Wildlife Refuge (MNWR). Title 18, United States Code, Section 372 is a crime 

of violence for purposes of the Bail Reform Act because it “has as an element of the 

offense the use, attempted use, or threatened use of physical force against the person or 

property of another” and it is a felony that, “by its nature, involves a substantial risk that 

physical force against the person or property of another may be used in the course of 

committing the offense.” 18 U.S.C. § 3156(a)(4)(A).

2. Weight of the Evidence

There is overwhelming evidence of defendant’s guilt, much of it documented by 

social media and defendant’s own statements.

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3. History and Characteristics of the Defendants

As set forth below, the defendant has no ties to Oregon. He traveled to Oregon in 

December 2015 to join the charged conspiracy where he remained until returning to

Arizona on approximately January 25, 2016, to visit his family. RITZHEIMER has long 

been associated with armed conflicts with the federal government and has repeatedly 

rejected the authority of the federal government, making him unsuitable for court-ordered 

supervision. He has demonstrated a willingness to engage in armed conflict throughout 

the United States in order to address what he describes as violations of the Constitution.

RITZHEIMER has been an active presence on social media supporting both the 

militia movement and his disdain for the Islam religion. RITZHEIMER organized 

multiple protests towards the Islamic Cultural Center of Phoenix (ICCP) in 2015 and 

promoted anti-Islamic sentiment in the Phoenix area. At those rallies, he was surrounded 

by men in full camouflage and body armor armed with assault rifles including members 

of the militia "Arizona Special Operations Group” led by Robert Deatherage who, along 

with his co-defendants Parris Frazier and Erik Foster, was detained by this court last 

summer in CR-15-00924-PHX-GMS. RITZHEIMER has been accepted by like-minded 

individuals, engaged in militia protests, and has since become an advisor for Operation 

Mutual Defense (OMD), a militia group. Below is a photograph taken on May 29, 2015, 

during defendant’s second protest which depicts an armed RITZHEIMER, wearing an 

anti-Islamic t-shirt sold on his website Rogue Infidel (see below), with one of his “body 

guards” identified as Robert Deatherage. 

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On September 21, 2015, in response to the United States’ proposed nuclear 

agreement with Iran, an open message written by RITZHEIMER was posted on 

Facebook in which he declared his intent to travel to Michigan to arrest Senator Debbie 

Stabenow. RITZHEIMER stated “[w]e are planning on arresting Senator Debbie 

Stabenow, who voted yes to the Iran Nuke Deal. She will be arrested for treason under 

Article 3 Section 3 of the Constitution. We have chosen her as our first target due to our 

strong ties with the Michigan State Militia and their lax guns laws that will allow us to 

operate in a manner necessary for an operation like this. After we successfully detain her 

we will continue to move across the country and arrest everyone involved with the Iran 

Nuke Deal. Even the President who brokered this deal. . . . I am fully prepared for 

whatever may come my way. Even if that means death. Because it will at least be for a 

noble cause.” (Attachment 7)

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On September 24, 2015, posted a video to his facebook calling for an indictment 

of those who supported the agreement with Iran and stated he was “armed and ready to 

go, to uphold the law.” (Attachment 8) On September 28, 2015, RITZHEIMER also 

appeared telephonically on the Pete Santilli show to discuss his intentions to arrest those 

involved with the nuclear agreement. https://www.youtube.com/watch?v=g9TOzWfUf8Q

(Attachment 9)

On December 2015, RITZHEIMER posted two videos to his facebook denouncing 

as unconstitutional the arrest of a fellow Marine, Schuyler Barbeau for possessing an 

unregistered firearm. See United States v. Schuyler Payaite Barbeau, CR-15-00391-RAJ, 

United States District Court for the Western District of Washington in Seattle. He called 

for a nationwide response to this illegal arrest and asked that Marines be ready for 

movement to Washington where Barbeau was being held captive without bail. 

(Attachments 10 & 11)

Not mentioned in the PTS report, RITZHEIMER faces a potentially lengthy prison 

sentence if convicted of the current charge which is punishable by a statutory maximum 

sentence of six years. Defendant has a strong incentive to flee due to the likelihood of a 

significant prison sentence if he is convicted. United States v. Townsend, 897 F.2d at 995

([F]acing the much graver penalties possible under the present indictment, the defendants 

have an even greater incentive to consider flight.”) 

Also, not disclosed in the PTS, is defendant’s income earned from his website 

www.rogueinfidel.com. Rogue Infidel’s website claims it is about “[d]efending the 

constitution against a domestic enemy. Doing what our government won't do while 

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remaining rogue.” This site sells anti-Islam items which can still be seen on its facebook 

page. However, the website currently asks for donations for RITZHEIMER’s legal fees 

and money to support his family. 

RITZHEIMER is willing to die over “his cause” and specifically addresses his 

belief that the Hammonds have been labeled terrorists in a video posted on December 31, 

2015. Not only does this video call for unification against the government but it is also a 

goodbye message to his family stating in part, “Your daddy swore an oath to protect and 

defend the Constitution against all enemies foreign and domestic.” He continues to 

explain that the oath does not mean he will only defend the Constitution when it is 

convenient or when that defense does not include death. In that video, RITZHEIMER

further stated, “I am 100% willing to lay my life down to fight against tyranny in this 

country.” He concludes by telling his family that he loves them and that no matter what, 

“just know that I stood for something, don’t let it be in vain.”

https://www.youtube.com/watch?v=sbGdMKpHDDE (Attachment 3)

4. Nature and Seriousness of the Danger to Any Person or the Community

Defendant RITZHEIMER should be detained as a flight risk and as a danger to the 

community. While the armed occupation of the MNWR continues, there remains a 

substantial danger that the defendant will return to the MNWR or another federal facility 

to assert his claimed authority over federal lands. His release poses substantial danger to 

the citizens of Harney County and elsewhere. Defendant RITZHEIMER is a leading 

member of the group and one of the first to occupy the MNWR. As noted in the 

complaint, RITZHEIMER was present in Oregon in December 2015 and remained until 

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January 24, 2016, when he left to visit his family in Arizona. His postings in social 

media have demonstrated a willingness to engage in armed conflict whenever he 

disagrees with government actions or with other religious beliefs. In a video posted on 

Youtube on October 8, 2015, an angry RITZHEIMER stated he carries a gun with him 

everywhere and encourages others to do so and states that it you threaten him or his 

family, you better get protection. https://www.youtube.com/watch?v=kg1q46oWnHoHe

(Attachment 12)

RITZHEIMER has called for armed resistance to fight against oppressive 

government by seeking arrests and indictments of law makers including the President. In 

his latest anti-government conflict, he trespassed on federal land to lead an armed 

resistance to fight against what he believed was an unconstitutional action by the United 

States. His leadership role in the conspiracy as well as his repeated disregard for the type 

of authority that would be attendant to pretrial supervision make him uniquely unsuitable 

for release. RITZHEIMER, despite his visibility, lacks ties to the District of Oregon.

This creates an inherent risk of flight. Moreover, his own statements demonstrate his 

unwillingness to comply with the terms of pretrial supervision and his willingness to die 

for his cause.

CONCLUSION

For the foregoing reasons, the United States respectfully requests that 

RITZHEIMER remained detained pending trial.

//

//

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Respectfully submitted this 2nd day of February, 2016. 

JOHN S. LEONARDO

 United States Attorney

 District of Arizona

 /s Lisa E. Jennis 

LISA E. JENNIS 

 Assistant U.S. Attorney

Certificate of Service

I hereby certify that on this date, I electronically transmitted the attached document to the 

Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of 

Electronic Filing to the following CM/ECF registrant: 

Elizabeth Kruschek

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