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April 18, 2016

Henderson Detention Center


PO Box 95050
Henderson, NV 89009-5050
Sent via First Class Mail and Fax to 702-267-4601
Henderson Police Department
PO Box 95050
Henderson, NV 89009-5050
Sent via First Class Mail and Fax to 702-267-5001
Re:

Incident and Discipline Report Appeal and Public Records Request


Report # HPD 4002
Inmate: Ammon Edward Bundy ID #0009119270

To Whom It May Concern:


This letter serves as Mr. Bundys appeal of the above-referenced Incident
and Discipline Report # HPD 4002 which is also attached for ease of reference.
Mr. Bundy is appealing his segregation status and demands to be housed in
general population immediately. Segregating Mr. Bundy is a violation of 42
U.S.C. 1983. Mr. Bundy will have an attorney present at any administrative
hearing that is held regarding this appeal. Accordingly, please advise our office
when this hearing is held so we may make someone available. Mr. Bundy needs
counsel present to inquire about the reasoning behind placing someone in solitary
confinement with no record of misbehavior or inability to get along with other
inmates..
This is also a request to allow attorney access to Mr. Bundy with a laptop
computer. This is essential to our effective representation of Mr. Bundy.
Discovery in the two complex cases he faces cannot be viewed with paper and a
pen. He must have access to a computer, during visits with counsel, to aid and
assist in his defense. If this request is not allowed, we request a hearing regarding
this matter.
We are also requesting that Mr. Bundy be allowed access to a computer to
type notes regarding his case. There are thousands of pages of discovery and many
hours of footage. Because of the complex nature of this case, Mr. Bundy needs to
have electronic notes so he can effectively distill and reference the massive
amount of discovery in this matter, and then use those notes to consult with
counsel. If this request is not allowed, we request a hearing regarding this matter.

Additionally, there have been allegations of a failure to feed Mr. Bundy.


Please consider this our request for administrative remedies, and our request for a
hearing on these allegations.
This letter also serves as a public records request and motion to preserve
records. We will need to use these documents in depositions of prison employees
should we be forced to file a lawsuit to protect Mr. Bundys rights. Please
provide our office with the following:
1) Any record of communication, including but not limited to email, phone
calls, any official correspondence, or internal memorandum, between any
member of the Henderson Police Department, or the Henderson Detention
Center with the US Marshalls service, the United States Attorneys Office,
any other government agency, or anyone else involved regarding Mr. Bundy
or Mr. Bundys case.
2) Any video surveillance of Mr. Bundy in the Henderson Detention Center
from the time of his arrival to present.
If there are any copying charges associated with this request, please contact
our office, and we will promptly remit payment. If the estimate of charges is more
than $65.00, please contact our office before continuing. If there are any questions
regarding this request, please contact our office. Thank you in advance for your
efforts.
Sincerely,
/s/
Michael Arnold
mike@arnoldlawfirm.com

Enclosure
Cc w/encl: Client

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