Ammon Bundy appeals an incident report placing him in solitary confinement with no record of misbehavior. He demands to be housed in general population immediately. Bundy also requests attorney access to a laptop computer and the ability to use a computer to type notes, citing the complex nature of his two cases. Additionally, Bundy alleges failure to feed and requests a hearing. This letter serves as a public records request for communications regarding Bundy and any video surveillance of him in detention.
Original Description:
4-18-2016 Mike Arnold Letter to Henderson Detention Center re Ammon Bundy
Original Title
4-18-2016 Mike Arnold Letter to Henderson Detention Center Re Ammon Bundy
Ammon Bundy appeals an incident report placing him in solitary confinement with no record of misbehavior. He demands to be housed in general population immediately. Bundy also requests attorney access to a laptop computer and the ability to use a computer to type notes, citing the complex nature of his two cases. Additionally, Bundy alleges failure to feed and requests a hearing. This letter serves as a public records request for communications regarding Bundy and any video surveillance of him in detention.
Ammon Bundy appeals an incident report placing him in solitary confinement with no record of misbehavior. He demands to be housed in general population immediately. Bundy also requests attorney access to a laptop computer and the ability to use a computer to type notes, citing the complex nature of his two cases. Additionally, Bundy alleges failure to feed and requests a hearing. This letter serves as a public records request for communications regarding Bundy and any video surveillance of him in detention.
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
Darryl Stephen Martin v. Richard Watson, Roberta Melton, and Brent Brown, Individually and in Official Capacities As Prison Officials, 993 F.2d 1551, 10th Cir. (1993)