Professional Documents
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Cliven Bundy Nevada Indictment
Cliven Bundy Nevada Indictment
Cliven Bundy Nevada Indictment
_ENTERED
DANIEL G.BOGDEN
M8 NSON
_RECEIVED
_SERVED ON
MAR -2 2010
NADIA .AHMED
DEPUTY
FAX:(702)388-6698
SEALED
SUPERSEDING CRIMINAL
INDICTMENT
Plaintift
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V.
CLIVEN D.BUNDY,
RYAN C.BUNDY,
AMMON E.BUNDY,
RYAN W.PAYNE,
VIOLATIONS:
tt
mS
lig
PETER ToSANTILLI,
MELVIN D.BUNDY,
DAVID H.BUNDY,
r.,
BRIAN D.CAVALIER,
BLAINE COOPER,
GERALD A.DELEMUS,
a Federal Officer;
STEVEN A.STEWART,
TODD C.ENGEL,
GREGORY P.BURLESON,
OSEPH D. 'SHAUGHNESSY,
MICAH L.McGUIRE,and
ASON D.WOODS,
18 U.S.C. S 924(c)
ERIC J.PARKER,
.
0.SCOTT DREXLER,
RICHARD R.LOVELIEN,
- Assault
on
Pi."ur* fi
Violence;
18 U.S.C. S 1951
Interfelence with
Defendants.
18 U.S.C. S 1952
Aid of Extortion;
)
)18
)
Interstate Travel in
to this SuPerseding
The Grand JurY eharges that at all times relevant
Indictment:
I.
SUMMARY
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1.
armed' assault
This superseding Indictment resulted from a massive
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and
one of the goals of the conspiracy was to thwart the seizure
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20 years, refusing to
lands. BUNDY had trespassed on the public lands for over
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S.sincelgg8,BUNDYwasunderfederalcourtordertoremovehis
ot follow' In 2013' a
trespass cattle, an Ord.er BUNDY reftrsed to recogntze
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that, in keeping
federal court issuecL two more Orders for removal, each declaring
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refused'
from the iand in the event BUNDY refused to do so. BUNDY
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of the
5, 2014. while it was ongoing, BUNDY and other leaders and organizers
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the impoundment'
the purpose of using force, threats, and intimidation to stop
cattle'
that law enforcement officers were abusing BUNDY and stealing his
against [the
travel to Nevada to "stop the abuse" by "making a show of force
in ord.er "to get them to back down" and "return the cattle'" By the
officers]"
with assault
morning of April 12, hundreds of people, including gunmen armed
other leaders
"Followers," conspiring with, and aiding and abetting him' and the
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intimidation.
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a crowd of
other Followers and gave them the order to get the cattle, directing
cattle were corralled'
hundred.s to travel more than five miles to the site where the
one group of Foilowers kept law enforcement officers occupied at the main
entrance of the site
group
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vulnerable poi.nt: a narrow entrance locatecl in a wash that ran under highway
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prevent
bridges. Seeing the assault unfold, the officers responded to the wash to
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entry.
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6.
in front
the officers. Some of these gunmen took tactically superior positions on high
behind other unarmed Followers. The most inllnediate threat to the offlcers came
froln the bridges where gunmen took sniper positions behind cOncrete barriers,
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7.
the Followers preSSed forward tO and against the wash entrance,demanding that
the officers leave and abandon the cattle,threatening to enter by force if they did
other unarmed bystanders WhO had accompanied the Fo1lowers, and wishing to
avoid the flreflght that was sure to fO110w if they engaged the gunmen on the
bridges and elsewhere who posed Such an obviOus threat to their lives,the officers
had no choice and were forced to leave and abandon the cattle to BUN]DY and his
CO
armed security patrols and checkpoints in and around BUN]DY's property tO deter
and preVent any future law enforcement actiOns against BUNDY or his co
conspirators and to protect his cattle fl oln flture remoVal actions, cattle he
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II.
THE DEFENDANTS
10.
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a resident
of
Arizonaand one of BUNDYs adult sons who affiIiated himself with Bundy Ranch-
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and affiliated with an organization that he called Operation Mutual Aid ('OMA")'
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Freeclom Fighters, ancl Media Relations personnel from Patriotic political activism
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Defendant Peter
California, who purported to be an internet blog radio host and affiliated with
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14.
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Defend.ant Melvin
Nevada and one of Cliven Bundy's adult sons who affiIiated himself with Bundy
Ranch.
1b.
and one of Cliven Bundy's adult sons who affiliated himself with Bundy Ranch.
16.
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Arizona who traveled to the State of Nevada with the intent to commit the crimes
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delineated herein.
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L7.
the crimes
who traveled to the State of Nevad.a with the intent to commit
delineated herein.
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intent to commit
New Hampshire who traveled to the state of Nevad,a with the
the crimes delineated herein.
19.
delineated herein.
20.
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the
Montana who traveled to the state of Nevada with the intent to commit
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Idaho who traveled to the State of Nevada with the intent to commit the crimes
delineated herein.
23.
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Defendant
herein'
Idaho who traveled to the State of Nevad.a to commit the crimes delineated
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Idaho
Defendant ERIC J. PARKER (..PARKER,,) was a resident of
who traveled to the State of Nevada with the intent to commit the crimes
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of
Defend.ant Gerald A. DELEMUS ("DELEMUS") was a resident
Defendant Todd
who traveled to the State of Nevada with the intent to commit the crimes
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delineated herein.
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of Arizona who traveled to Nevada with the intent to commit the crimes set forth
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herein.
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25.
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)
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a resi.dent of
Defendant Micah L. McGUIRE (..MCGUIRE,,) was
of Arizona
Defendant Jason D. WOODS ('5\MOODS") was a resident
III.
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28.
the United
"Fed.eral public land" or "public land" was land owned by
including'
states and managed through various agencies of the united states,
of Interior, Bureau of
Land
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Management(..BLM,,)andNationa}ParkService(..NPS,,).
29.
Agents
The BLM and NPS employed Rangers, officers, and special
management'
to enforce federal laws and regulations on public land und'er their
30.
BLM and NPS Rangers, Officers, and Special Agents were "federal
by law
they were officers, agents, and employees of the united states authorized
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or prosecution of
to engage in or supervise the prevention, detection, investigation,
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public land near Bunkerville, Nevada, under the management of BLM' The
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it
United States has owned the land. comprising the Allotment since 1848, when
of Guadalupe Hidalgo'
was acquired from the nation of Mexico und.er the Treaty
and has never relinquished ownership'
32.
was an area
The Lake Mead National Recreational Area ("LMNRA")
under the
of fed.eral public }and located near or adjacent to the A1lotment'
land comprising the
management of the NPS. The united states has owned the
it
IV.
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TH FOU
BLM and to pay fees to the United States to graze cattle on the Bunkerville
Allotment. Grazing cattle without
84.
"District Court" or
States District Court for the District of Nevada (herein after
,,Fed.eral Court") Ordered BUNDY
86. In 1ggg, the District Court fined BUNDY for each day he refused to
by
remove his cattle. BUNDy refused to pay the fines and continuecl to trespass
27. By
2012,
spread
into the LMNRA where BUNDY kept and grazed them year-round, refusing to
to remove his trespass cattle permanently from the LMNRA and the other
affirmed the 1gg8 and 1999 Orders that required. him to remove his cattie
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re-
permanently from the Aliotment. Both Orders declared that, in keeping with the
law, the United States was authorized to seize and remove BUNDY's trespass
cattle if he did not comply with the Court's Orders. One of the Orders expressly
stated that BUNDY was "not to interfere" with any removal.
gg. BUNDY
40. In keeping with the iaw and the 2013 federal Court Orders,
the BLM
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impoundment'
estimated that it would take a month or more to compiete the
42. It was part of the plan that BLM wouid. establish a base of operations
public lands
(hereinafter referred to as "the Impoundment Site") located on the
commonly
near Bunkervilie, about 7 miles away from Bundy Ranch in an area
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into a contract with a civilian contractor in Utah to round-up and gather the
trespass
people and
gather and move the trespass cattle from public land into corrals
Impound.ment site where they would be held
at
the
be
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further transported.
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4b. It was part of the plan that on March 20, 2074, BLM entered into a
contract for the services of an auctioneer
the
in Nevada to the
contract auctioneer in Utah, who would then sell them at public sale.
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46. It was part of the plan that BLM would use BLM and NPS Rangers,
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including securing the cattle at the Impoundment Site and protecting the civilian
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47. It
was Part of the Plan that BLM designated the SPeciaI Agent-in-
Charge
region (hereinafter
the "SAC") to
\rI.
lead
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connection
with legal
proceedings
culminating in the 2013 Court Ord.ers, BUNDY threatened to interfere with any
impoundment
the
t0
impoundment. When asked whether that included soliciting support from others
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that
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publically that he "[was] ready to do battle" with the BLM and he would "do
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bl.
On Mar,ch
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the Special Agent was available to answer any questions about the impoundment
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with him to prevent the BLM from removing the trespass cattle.. When
whether his use of "whatever
it
asked
it
want."
miles away" and he was in a "range war" with BLM that could "last a }ong time'"
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guts to try
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. . . I'11 do whatever
it
takes."
.[i]t'slikethey'restagingforawar...Itoldtheml'ddowhateverittakes...I'll
stick with that."
VII.
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A.
bb.
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06.
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to threaten fbrce and violence and use force and violence to: (1) impede, obstruct,
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ancl interfere
BUNDY and his coofficers from taking future law enforcement actions against
from exercising
conspirators and prevent by force and threats of force, the BLM
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B.
of
the
people (hereinafter
conspiracy recruited, organized, and led a force of hundreds of
prevent the
referred to as "Followers") to threaten and use force and violence to
their consent
Iaw enforcement officers from discharging their duties and to coerce
care
to abandon the cattle that were, pursuant to court order, Iawfully in their
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and
As a part of the mannel and means of the conspiracy, the leaders
a.
travel to Bundy
other. Followers, that is, to encourage, counsel, and incite others to
Ranch for the unlawful purposes of interfering with impoundment operations,
violence
obstructing the execution of fecleral Court Orclers and using force and
against federal law enforcement officers while they were performing their duties'
b.
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knowingly broadcast false, deceitful, and deceptive images and messages for the
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c.
for the
encourage, counsel, and incite gunmen to bring their guns to Bundy Ranch
execution of federal Court Orders, and using force and violence against federal law
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d.
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e.
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f.
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g.
and aim firearms, includ.ing assault rifles, for the purpose of extorting federal law
enforcement officers.
h.
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and aim firearms, including assault rifles, for the purpose of assaulting federal
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security checkpoints for the purpose of using threats, force, violence, and
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the conspirators, prevent the execution of federal Court Orders, and prevent law
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bg.
referred to herein as "gunmen," traveled to Bundy Ranch with firearms for the
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the
purpose of joining the conspiracy and to carry, use, or brandish firearms for
)a
extorting federal law enforcement officers while in the performance of their duties'
C.
60. BUNDY was the lead.er, organizer, and chief beneficiary of the
of
conspiracy, possessing ultimate authority over the scope, manner, and means
conspiracy who, among other things: recruited gunmen and other Followers;
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interferecl with impoundment operations through threats and use of force and
violence; interfered with impoundment operations by attempting to extort BLM
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and"
to gunmen; led
the
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68. SANTILLI was a leader and organrzer of. the conspiracy who, among
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other things: recruited gunmen and other Followers using the internet and other
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threatened federal Iaw enforcement officers; and participated in the assauit and
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64.
Followers;
of the conspiracy who, among other things: recruited gunmen and other
interfered. with impoundment operations through threats and use of force and
contractors; led the armed assault against federal law enforcement officers at the
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6b.
conspiracy who, among other things: recruited and organized gunmen and other
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conspiracy who, among other things: recruited and organized gunmen and other
Followers; conducted reconnaissance missions; recruited Followers; and provided
personal protection for members of the criminal enterprise.
67.
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of the
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Followers; ied gunmen and other Followers in the assault and extortion of federal
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members of the criminal enterprise; and organized armed patrols and security
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checkpoints.
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68.
2
1
and provided
conspiracy who, among other things: recruited, organized, trained
armed
Iogistical support to gunmen and other Followers and organized and led
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70.
71.
72.
impeded,
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impeded,
74.
impeded,
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herein'
officers whiie in the performance of their d,uties, as described
76.
law enforcement
intimidated, interfered with, assaulted and extorted federal
herein'
officers while in the performance of their duties, as described
D.
77. It was a part of the conspiracy and for the purpose of carrying out the
to be performed' the
objects of the conspiracy, the defendants performed, or caused
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1.March28toApril11:TheConspiratorslnterferedwith
Deception to
Impoundrnent operations and Used Deceit and
Recruit Followers.
and others
working with them, blocked a convoy of vehicles carrying horses and equipment
intended for use in impoundment operations, confronting and threatening civilian
contractors, endangering the safety of the personnel in the convoy, and interfering
7g.
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them with false, deceitful and d.eceptive statements to the effect that the BLM was
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g0.
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traveled from Nevada to Utah to threaten force, violence and economic harm to
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the contract auctioneer providing services to the BLM, by, among other things,
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entering upon the contractor's property for the purpose of interfering with
interfering with business operations, and threatening to shut down the business
81.
if
against federal law enforcement officers by publically stating, among other things:
,,I',ve
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done quite a
bit
so
far to keep my cattle, but I guess it's not been enough . '
'
it takes to keep my
gZ.
83.
convoy
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and refusing to leave the area when asked to do so. Failing to leave after repeated
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arrest to be broadcasted over the internet, combining them with false, deceitful
and deceptive statements to the effect that the BLM supposedly: employed snipers
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against Bundy family members; used excessive force during the arrest; and
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85.
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Keeper's
time to make a stand against the feds now is the time. Good so let's go there 100
and land."
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g6.
g7.
Nevada, by telephone.
88.
operations, stating falsely, among other things, that the Bundy Ranch was
surrounded by BLM snipers, that the Bundy family was isolated, and that the
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Bg.
established
along
Nevada State Route 170, a state road that also served as the main route between
the Impoundment Site and the public land where impoundment operations were
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taking place. Strategically located between the Impoundment Site and various
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ilgress and egress points to public land, the location of site served as both
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potential choke-point for disrupting BLM convoys. Conspicuous for, among other
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things, a stage and two tall flagpoles, one of which flew the Nevada State flag
1A
LA
Staging Site") served as a base of operations from which the conspirators made
at
speeches, received and organized gunmen and other Followers as they arrived
Bundy Ranch, and gathered and organized gunmen and other Foliowers before
contacted
SANTILLI
about
going to Bundy Ranch, stating, "What do you think about getting a movement
puffing and bullshit over the microphones and computers and go down and do
..
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contacted
11
2014,
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word.s and images over the internet
broadcasted
and
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other Followers. Using deceit, deception, and threats to encourage and incite
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others to travel to Bundy Ranch for unlawful purposes, BUNDY toid listeners,
among other things, that: "they have my house
surrounded
the federal
government is stealing my property . . . [the BLM] are armed with assault rifles .
.
they have snipers . . . I haven't cailed no miiitia but, hey, that look like where we
here
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are
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back . . . somebody is going to have to back off . . . we the people will put our boots
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whatever it takes."
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people
do
incite listeners to travel to Bundy Ranch for unlawful purposes, telling listeners,
"if this is not the issue right now where we stand and
must
fight to the absolute death there is no other option; the federal government
o'k' '
Nevada . . . if you're in Nevada and can legally carry, get weapons out there,
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it to be peaceful it is by their
in clark county,
Nevada . . - they
'
will leave or
else."
94.
in
Pennsylvania to another person who referred to himself as one of the leaders
first
OMA, stating, among other things, that it was "time to invite everyone to the
annual patriots (sic) picnic at the Bund5r Ranch" and telling the OMA leader that
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the Bundys "still want helP'"
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95. on or about April 8, 2014, and for the purpose of recruiting gunmen
and other Followers, PAYNE sent a message over the internet, stat'ing that he
had spoken with BUNDY and that "he knows we're corning and has opened his
land up to everyone willing . . . oMA is moving . . . not going public with this until
more are enroute."
96.
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OMA members stating: "we have made the decision to mobilize in Nevada, units
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are und,erway as
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but that number is [gr]owing by the hour." The message provided directions and
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97.
traveled from
gg.
BUNDY in Nevada.
and.
SANTILLI met
with the SAC. SANTILLI stated that he was acting as a liaison between BUNDY
and the
asked:
to clo if 10,000 people show up? . . . Are you prep,ared for this?" SANTILLI added:
unless
and constitutional."
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108. On or about April g, 2A74, and for the purpose of encouraging and
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inciting gunmen and others to travel to Bund.y Ranch for unlawful purposes, the
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Bundy family has requested. help from militia groups including Operation Mutual
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Aicl, B Percenters club, freeclom fighters, and other operations to come and stand
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104. On April g, 2014, and for the purpose of encouraging and inciting
gunmen ancL others to travei to Buncly Ranch for unlawful purposes, SANTILLI
broaclcasted a message over the internet, stating, among other things: "the BLM
knows
travelecL
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105. On or about Aprii g,2O\4, R. BUNDY, and others working with him,
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I fully
we
for a second time from Nevada to Utah to threaten force, violence and
economic loss to the contract auctioneer providing services to the BLM by, among
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gunmen
and encouraging ancl inciting others to travel to Bundy Ranch for unlawftrl
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purposes,
SANTILLI
broadcasted
other things: "now is the time to show up for something iike this
thousand people to come
here . . I
. we need ten
respondtothiscall ...it'stimetomakeastandagainsttyranny...weneedtolet
everyone know that BLM has zero authority."
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interfered with, impeded and intimidated federal officers by, among other things:
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in
impotrndment
108. On or about April g, 2014, and for the purpose of recruiting gunmen
inside.
in
and inciting others to travel to Bundy Ranch for unlawftrl purposes, SANTILLI
broadcasted a message over the internet, stating, among other
serious about stopping the convoy . . . [the BLM] were caught off guard and tried
to push past
retreated
us
. they couldn't do it
will
fear is if we don't respond . . . they retreated and will come back with a bigger
force
them
with numbers
. we want BLM to
stake
. we can win
are fuliy armed are here . . . it's good to watch the BLM with its tail between its
legs...getouthere...thisisgoingtogetexciting...ultimatelygetthefedsto
Ieave."
109. On April 10, 2014, and for the purpose of recruiting gunmen and
encouraging and inciting others to travel to Bundy Ranch for unlawful pulposes,
1.
of all
personnel responding
Protestors, extended family, and friends.
protection
in
ie.
2.
3.
To secure and return to Mr. Bundys (sic) ranch the mounting number
private
contractors.
These objectives are in cohesion
110.
On or about
April
and encouraging and inciting others to travel to Bundy Ranch for unlawful
purposes, SANTILLI broadcasted a message over the internet, stating, among
here
members here now . . . where we will fail is for us not to not match the BLM force
. . we need a show of force . . . we ctid a recon and found that BLM have hundreds
we have about 50
.
of vehicles
. they
will
come back
. we need tens of
for the ultimate moment . . . we can win with numbers . . . get out here no matter
111.
On or about
ancl encouraging ancl inciting others to travel to Bundy Ranch for unlawful
purposes, SANTILLI broadcasted. a message over the internet, stating, among
BLM believes
[BLM]
ll1.
will
if we have
Buncly Ranch in Nevada with firearms and with the intent to commit the crimes
set forth herein.
tL4.
Hampshire to Nevacla with firearms anci with the intent to commit the ci'imes set
forth herein.
115.
On the morning of
April Ll,
2014,
threatened him, stating, among other things: "we are going to have a face-to-face
confrontation
. we have thousands of
people
this is non-
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negotiable if you make the decision to go face-to-face and someone gets hurt
tell D.C. that the justification for this is
we are going to hold you responsible .
I'm relaying a message if anyone is acting
from a corrupt court
unconstitutionally they witl be arrested . . . I came here to allow you to prevent
Nevada, many armed with assault rifles and other firearms (hereinafter also
referred to as "gunmen").
tl7.
By on or about April
received and organized the gunmen, placing them into camps from which to
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him, organized gunmen into patrols and security checkpoints to provide security
to the conspirators and their criminal enterprise'
and
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ENGEL traveled from Idaho to Bundy Ranch in Nevada with firearms and with
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121,.
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BURLESON traveled from Arizona to Bundy Ranch in Nevacla with firearms and
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Z.
722. It was further a part of the conspiracy that on April 12, 2014, the
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head of cattle and had them corralled at the Impoundment Site, awaiting further
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Followers at the Staging Site where he told them that "God [is] going to be with
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us" and that it was time "to take our land back." He then commanded his
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people"
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(Followers riding horses) would leave the Staging Site and travel a dirt road to the
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Toquop Wash, the location of the Impoundment Site, a distance of about 3.5 miles.
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Whiie that was happening, so commanded by BUNDY, the gunmen and other
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Followers were to travel the highway by vehicle, a distance of about 5 miles, and
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"shut down the freeway" at the Impoundment Site. The gunmen and other
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21
22
/)
Followers, so directed by BUNDY, were then to meet with the "horse people" in
the Toquop Wash.
The
24
29
Site, jamming the roads and slowing traffic on northbound Interstate-15 ("I-15") to
a trickle, making it difficult for state and local law enforcement vehicles to
respond. When the gunmen and other Followers arrivecl at the Impoundment Site,
they jgmped out of their vehicies and many of them moved quickly on foot to
carried and brandished assault rifles, from entering at the main entrance to the
Impoundment Site.
L28. Around
the area across from the main entrance to the Impoundment Site to an area a few
hundred yards east and below the main enttance, in the Toquop Wash under the
northbound I-15 bridge. There, A. BUNDY waited while gunmen and other
Foliowers, seeing the movement of the others to the wash, moved there to join
him. As gunmen and other Followers gathered in the wash, A.. BUNDY
instructed them that they were to wait there trntil the Followers on horseback
arrived, as his father had stated at the Staging Site.
Lzg. About 150 yards across from A. BUNDY's position was a makeshift
metal rail gate that traversed the wash between the pillars that supportecl the
Impoundment. Site from the wash. The gate was manned only by two officers who
imrnediately called for backup when they first noticed A. BUNDY move to the
wash with his Followers. As the number of Foliowers in the wash grew, mol'e
30
the
officers respond.ed to the gate, eventuaily forming a line that started about 15 to
20 yards behind the gate and extend.ed up the wash, perpendicular to the gate.
upon
the Impoundment Site, many of the Followers openly brandishing assault. rifles,
others bearing side arms, the combined group grossiy outnumbering the
approximately b0 officers that had moved to the wash to protect the gate. More
and more of the Followers moved to the wash while still others began flooding onto
the southbound I-1b bridges and bridge skirts, their movement there facilitated by
10
11
horseback arrived at the wash and joined with A. BUNDY',s group. Then, the
t2
combined force of about 270 Followers
l3
t4
on
towald the officers at the gate. The officers immediateiy began ordering the crowd
15
16
l7
18
l9
to clisperse. Using loudspeakers, they toid the Followers that they were in a closed
alea, in violation of a Court Order. Still they came. As the Followers moved
closer to them, the officers observed the gunmen moving with them and began
calling otrt their positions to each other and to theil dispatch center, On the
20
loudspeaker, officers tolcl the Followers that they had spotted the gunmen and
21
orcLered
22
23
24
them ali to leave. The commands went unheeded and the gunmen and
then formed a human line that stretched aci'oss the bottom of the wash. There
31
they waited.
2
J
formation across the bottom of the wash. A. BUNDY and his group quickly filed
into the line. At this point, the Followers numbered about 200, and the law
enforcement officers numbered about 50. The officers continued to call out any
gunmen they observed. They called out gunmen with "long guns" and sidearms
l0
l1
moving in and out among the unarmed Followers on foot, some of them taking
high ground. They called. out gunmen with "long gLlrls" moving on the bridges and
then disappearing. One of the officers called out that they soon would
outgunned. As more gunmen moved to the wash, the officers reported that there
were "more guns than they could count."
l2
l3
l4
l5
l6
t7
l8
be
the Followers screaming at the officers, demanding that they release BUNDY's
cattle.
135. The officers at the gate were dangerously exposed. They were in the
open on low ground at the bottom of the wash, below highway bridges that
19
towered mor,e than 40 feet above them and surrounded on the sides by steep
20
embankments of high ground. The terrain acted iike a funnel with them at the
21
bottom and no natural cover or conceaiment to protect them from the gunmen on
22
the high ground, their only protection being their body armor and the vehicles
/)
24
while more than 20 of them carried or brandished firearms on the bridges. The
officers at the gate could readily observe gunmen bobbing up and down from
behincl the concrete baniers that bordered the northbound I-15 bridge, indicating
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
to the officers that the gunmen were acquiring, and determining the range to,
and
body armor, and the superior position of the gunmen on the bridge above, all
caused the offrcers to fear immediate bodily harm or death.
L37. Around
12:15 p.m. and after hearing from his officers at the gate
that
thei'e now were "too many guns to count" in front of them, the SAC was forced to
decide to give in to BUNDY's demands and release the cattle in order to prevent
19
death oi'injury to his officers and others. The SAC moved from the main entrance
20
area, down the wash ancl to the gate, his purpose being to find a way to create
21
space between his officers and the gunmen and other Followers so the officers
22
could safeiy disengage and avoid any potential bloodshed while he found a way to
23
24
weapons
2
3
pointed at him and gunmen moving to higher ground, all causing the SAC to fear
immediate bodily harm or death.
1gg. When the SAC arrived at the gate, A. BUNDY came out from
the
Iine and moved to the gate. The line of Followers advanced with him, yelling,
6
7
8
9
10
11
12
13
14
15
16
17
18
to disperse as
ordered. The gunmen on the bridges took sniper positions, some behind the
concrete barriers on the bridges and others under the bridges, tucked
in
the
140. As A. BUNDY
in the wash
moved
with him, openly brandishing their rifles and taking over-watch positions on the
high ground within full view of the tactically disadvantaged officers, the snipers
on the bridges now aiming their assault rifles directly at the officers below.
Seeing the combined force arrayed against them
than 400 Followers, more than 270 ofthe Followers in the wash directly in front of
them, more than 60 glrnmen among the crowd carrying or brandishing rifles
or'
zeroed-in
on the officers,
gunmen
19
inter.mingled
20
21
22
be shot and
23
24
firefight that would kill or injure unarmed people. Unable to surgically remove
killed. They were stymied - prevented from shooting the gunmen who
threat to their lives out of concern they would spark a
34
dangerousiy exposed and tactically inferior position, the officers knew they were
147. Arriving at the gate, A. BUNDY and D. BUNDY met with the
SAC
who explained to A. BUNDY and D. BUNDY that he would work with him to
gate so the officers could safely disengage. A. BUNDY and D. BUNDY refused
and d.emanded that the officers ieave first, A. BUNDY stating, among other
9
10
l1
t2
l3
t4
l5
r8
19
if the officers
remained longer, the SAC was forced to give in to their demands and ordered his
officers to leave, abandoning the post, the impoundment site, and the cattle to
BUNDY.
743. Having been forced to meet the conspirators' demands, the SAC met
t6
17
with D. BUNDY ancl R. BUNDY near the main entrance to the Impoundment
Site to negotiate the departure of the law enforcement officers. While the
Followers, including gunmen, held their position below at the gate, R. BUNDY
70
demand.ed that the SAC order his officers leave the Impoundment Site
2l
hours.
within two
11
LL
23
the officers left the Impoundment Site quickly ancl then organized the FoiLowers to
24
L4b. The law enforcement officers were thus forced to abandon the
Impoundment Site and the cattle to the conspirators and their Followers. R'
corrals, where they opened. the gates to release the cattle. M. BUNDY then led the
Followers on horses to drive the cattle out of the Impoundment Site. Thereafter,
6
7
8
9
10
The
and
146. It was further a part of the conspiracy that following the April
12
11
assault and extortion, the defendants took such other actions as necessary to
12
protect themselves and their iil-gotten gains and to further interfere with and
13
14
defendants
15
16
17
18
19
20
21
22
23
24
148. From Aprit 12 to at least the end of May 2014, the defendants,
including DELEMUS, CAVALIER and COOPER established armed checkpoints
and security patrols to prevent and deter law enforcement actions against the
conspirators, including recovering the extorted cattle.
l4g.
estabiished arrnect checkpoints and security pati'ols to prevent anci deter law
enforcerrent actions against the conspiratots, including recovering the extorted
36
cattle.
,
D
4
5
statements to the SAC, threatening similar assaultive conduct in the event the
BLM attempted further law enforcement actions against BUNDY and his
conspirators.
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Superseding
Indictment, the defendants made public statements threatening that they would
continue to interfere with federal law enforcement actions against them or the
cattle.
Superseding
Superseding
protect, and prevent the impoundment of the extorted cattle and such other
trespass cattle that are subject to the 2013 Court Orders.
COUNT ONE
Conspiracy to Commit an Offense Against the United States
(Title 18, United States Code, Section 371)
21
I54.
22
23
date of this Superseding Indictrnent, in the State and Federal District of Nevada
24
and elsewhere,
37
CLIVEN D.BUNDY,
RYAN CoBUNDY,
AMMON EoBUNDY,
RYAN WoPAYNE,
PETER ToSANTILLI,Jr
MELVIN D.BUNDY,
DAVID H.BUNDY,
BRIAN Do CAVALIER,
BLAINE C00PER,
GERALD A.DELEMUS,
ERIC .PARKER,
0.SCOTT DRttER,
RICHARD RoLOVELIEN,
STEVEN AoSTEWART,
TODD CoENGEL,
GREGORY P.BURLESON,
JOSEPH D.0'SHAUGHNESSY,
MICAH Lo McGUIRE,and
JASON Do W00DS,
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
a.
riolence,
d.
e.
and a1l ofthose comprising the offenses charged in Counts Three through SiXteen.
COUNT T'V0
158.
date of this Superseding lndictinent,in the State and Federal District of Nevada
and elsewhere,
CLIVEN DoBUNDY,
RYAN C.BUNDY,
AMMON E.BUNDY,
RYAN WoPAYNE,
PETER ToSANTILLI,Jr.,
MELVIN D.BUNDY,
DAVID HoBUNDY,
BRIAN Do CAVALIER,
BLAINE C00PER,
GERALD A.DELEMUS,
ERIC JoPARKER,
0 SCOTT DREXLER,
RICHARD RoLOVELIEN,
STEVEN AoSTEWART,
TODD C.ENGEL,
GREGORY P.BURLESON,
JOSEPH D.0'SHAUGHNESSY,
MICAH Lo McGUIRE,and
JASON Do W00DS,
defendants herein, did knowingly and willf 11ly combine, conspire, confederate,
39
and agree with each other, and with others known and unknown to the Grand
enforcement officers from discharging the duties of their office under the United
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
law
States, and to induce by force, intimidation, and threats, federal law enforcement
officers to leave the place where their duties were required to be performed, that
is, enforcing and executing federal Court Orders to remove trespass cattle from
federal public lands and enforcing federal laws and regulations on federal public
lands in and around the Allotment.
CLIVEN DoBUNDY,
RYAN C.BUNDY,
AMMON E.BUNDY,
RYAN WoPAYNE,
PETER ToSANTILLI,Jr
MELVIN DoBUNDY,
DAVID HoBUNDY,
BRIAN Do CAVALIER,
BLAINE C00PER,
GERALD A.DELEMUS,
ERIC JoPARKER,
0 SCOTT DREXLER,
RICHARD RoLOVELIEN,
STEVEN A.STEWART,
TODD C.ENGEL,
40
GREGORY P.BURLESON,
JOSEPH D.0'SHAUGHNESSY,
MICAH Lo McGUIRE,and
JASON Do W00DS,
2
3
4
5
6
7
8
defendants herein, aided and abetted by each other, and by others known and
unknown to the Grand ury,did knowingly use and carry firearllns,which wel.e
brandished,during and in relation to a crilne of violence for which they lnay be
prosecuted in a court ofthe United States,that is,conspiracy to impede and itture
an officer,in violation of Title 18,United States Code,Section 372,as charged in
10
11
2.
COUNT FOUR
12
13
14
161.
15
16
17
18
19
Nevada,and elsewhere,
CLIVEN DoBUNDY,
RYAN CoBUNDY,
AMMON E.BUNDY,
RYAN WoPAYNE,
20
MELVIN D.BUNDY,
21
defendants herein, aided and abetted by each other, and by others known and
22
unknown to the Grand ury,did use a dangerous and deadly weapon and lorcibly
23
24
intilnidate, and interfere with federal law enforcement officers,while they were
engaged in and on the account of the perforrnance of their offlcial duties,that is,
COUNT FIVE
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
164. On or about Apri1 12, 2014, in the State and Federal District of
Nevada,and elsewhere,
CLIVEN D.BUNDY,
RYAN C.BUNDY,
AMMON E.BUNDY,
RYAN W.PAYNE,
PETER ToSANTILLI,Jr
MELVIN D.BUNDY,
DAVID H.BUNDY,
BRIAN Do CAVALIER,
BLAINE C00PER,
GERALD A.DELEMUS,
ERIC J.PARKER,
0 SCOTT DREXLER,
RICHARD R.LOVELIEN,
STEVEN AoSTEWART,
TODD CoENGEL,
GREGORY P.BURLESON,
JOSEPH D.0'SHAUGHNESSY,
MICAH L. IcGUIRE,and
JASON Do W00DS,
,
23
defendants herein, aided and abetted by each other, and by others kno vn and
24
lnknown to the Grand ury,did use a deadly and dangerolls weapon and forcibly
42
assault, resist, oppose, impede, intinlidate, and interfere with federal law
enforcement officers while they were engaged in, an4 0n the account Ot the
performance of their offlcial duties, that is, guarding and protecting the
of federal Court Orders to remove cattle froln the A1lotment,as described herein.
6
7
COUNT S
9
10
11
12
13
14
15
165.
166.On or about Apri1 12, 2014, in the State and Federal District of
Nevada,and elsewhere,
CLIVEN D.BUNDY,
RYAN C.BUNDY,
AMMON EoBUNDY,
RYAN WoPAYNE,
PETER ToSANTILLI,Jr.,
23
MELVIN DoBUNDY,
DAVID H.BUNDY,
BRIAN Do CAVALIER,
BLAINE C00PER,
GERALD A.DELEMUS,
ERIC JoPARKER,
0.SCOTT DREXLER,
RICHARD R.LOVELIEN,
STEVEN AoSTEWART,
TODD C.ENGEL,
GREGORY P.BURLESON,
JOSEPH D 0'SHAUGHNESSY,
MICAH Lo McGUIRE,and
JASON Do W00DS,
24
defendants herein, aided and abetted by each other, and by others kno vn and
16
17
18
19
20
21
22
43
unknown to the Grand Jury, did. knowingly use and carly a firearm, which was
brandished, during and in relation to a crime of violence for which they may be
prosecuted
vioiation of Title 18, United States Code, Section 111(aX1) and ft), as charged in
Count Five of this Superseding Indictment.
Atl in violation of Title 18, United States Code, Sections 92a(cX1)(AXii) and
2.
COUNT SEVEN
Threatening a Federal Law Enforcement Officer
(Title 18, United States Code, Sections 115(a)(1)(B) and 2)
168. On or about Aprii 11, 2A74, in the State and Federal District of
Nevada, an elsewhere,
CLIVEN D. BUNDY,
RYAN C. BUNDY,
AMMON E. BUNDY,
RYAN W. PAYNE, and
PETER T. SANTILLI, JT.,
ciefend"ants herein, aided and abetteci
unknown to the Grand Jury, did threaten to assault the SAC, a federal iaw
enforcement officer', ancl such othei' federai law enforcement officers associated
with impoundment
operations,
and
interfere with saicl law enforcement officers while engaged in the performance of
their official dr,rties and with the intent to retaliate against said law enforcement
officers on account of the performance of their duties,
in that SANTILLI
confronted tite SAC at the Impoundment Site, threatening with words and actions
to the effect that thousands would confront the officers with the potentiai for
violence, as described herein.
All in violation of Title 18,United States Code,Sections l 15(a)(1)(B)and 2.
COUNT EIGHT
Threatening a Federal Law Enforcement Officer
(Title 18, United States Code, Sections 115(a)(1XB) and 2)
CLIVEN D.BUNDY,
RYAN C.BUNDY,
AMMON E.BUNDY,
RYAN W.PAYNE,
PETER ToSANTILLI,Jr
MELVIN DoBUNDY,
DAVID H.BUNDY,
BRIAN Do CAVALIER,
BLAINE C00PER,
GERALD A.DELEMUS,
ERIC JoPARKER,
0 SCOTT DREXLER,
RICHARD RoLOVELIEN,
STEVEN A.STEWART,
TODD C.ENGEL,
GREGORY P.BURLESON,
JOSEPH D.0'SHAUGHNESSY,
MICAH Lo McGUIRE,and
ASON Do W00DS,
,
defendants herein, aided and abetted by each other, and by others known and
unknown to the Grand ury, did threaten to assault the SAC, a federal law
enfbrcement officer, and such other fedel'al law enforcelnent officers associated
interfere with said law enforcement offlcers while they were engaged in the
performance of their official duties and with the intent to retaliate against said
federal Court Orders to remove cattle from the Allotinent as described herein.
7
8
9
10
11
12
13
14
COUNT NINE
172. On or about April 12, 2014, in the State and Federal District of
Nevada,and elsewhere,
CLIVEN D.BUNDY,
RYAN C.BUNDY,
AMMON E.BUNDY,
RYAN W.PAYNE,
PETER ToSANTILLI,Jr
22
MELVIN D.BUNDY,
DAVID HoBUNDY,
BRIAN Do CAVALIER,
BLAINE C00PER,
GERALD A.DELEMUS,
ERIC JoPARKER,
0 SCOTT DREXLER,
RICHARD RoLOVELIEN,
STEVEN AoSTEWART,
TODD CoENGEL,
GREGORY P.BURLESON,
JOSEPH D 0'SHAUGHNESSY,
MICAH Lo McGUIRE,and
JASON Do W00DS,
23
defendants herein, aided and abetted by each other, and by others known and
24
unknown tO the grand jury, did knowingly use and carry firearms,which were
15
16
17
18
19
20
21
46
brandished, during and in relation to a crime of violence for which they may be
prosecuted
enforcement officer,
115(a)(1)(B), as charged
AII in vioiation of Title 18, United States Code, Sections 92a(cX1)(A)(ii) and 2.
COUNT TEN
Obstruction of the Due Administration of Justice
(Title 18, United States Code, Sections 1503 and 2)
7
8
l0
11
l2
r3
14
CLIVEN D. BUNDY,
RYAN C. BUNDY,
AMMON E. BUNDY,
RYAN W. PAYNE,
PETER T. SANTILLI, Jr., and
DAVID H. BUNDY,
and abetted by each other, and by others known and
15
t6
unknown to the Grand Jury, did corruptly, and by threats and force, and by
17
18
l9
20
21
22
in that
the
BUNDY, D. BUNDY, and others working with them, atternpted to impede and
obstruct a BLM convoy at or near Nevada State Route 170 while the convoy was
engaged impoundment operations, as clescribed helein.
23
47
COUNT ELEVEN
Obstructi.on of the Due Administration of Justice
(Title 18, United States Code, Sections 1503 and 2)
2
3
CLIVEN D. BUNDY,
RYAN C. BUNDY,
AMMON E. BUNDY,
RYAN W. PAYNE,
PETER T. SANTILLI, Jr., and
MELVIN D. BUNDY,
l0
defendants herein, aided and abetted by each other, and by others known and
l1
unknown to the Grand Jury, did corruptly, and by threats and force, and by
12
13
t4
clefendants threatened force and violence ancl used force and violence to impede
l5
and thwart the execution of federal Court Orders, in that the defendants did
l6
impede ancl obstruct, and attempt to impede and obstruct, a BLM convoy while
17
was engaged
7
8
18
l9
20
21
22
Z)
in
in that
the
it
as
described herein.
All in violation
of
2.
COUNT TWELVE
Obstruction of the Due Administration of Justice
(Tit1e 18, United States Code, Sections 1503 and 2)
24
48
Nevada,
CLIVEN DoBUNDY,
RYAN C.BUNDY,
AMMON E.BUNDY,
RYAN WoPAYNE,
2
3
PETER ToSANTILLI,Jr
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
defendants herein, aided and abetted by each other, and by others known and
unknown to the Grand Jury, did corruptly, and by threats and force, and by
threatening collnlnunications, influence, obstruct, and ilnpede, and attempt to
influence, obstruct, and impede, the due adFniniStration of justice, in that the
defendants threatened force and violence and used force and violence to impede,
obstruct and thwart the execution of federal Court Orders by assaulting and
extorting federal officers at the lmpoundment Site,as described herein.
All in violation of Title 18,United States Code,Sections 1503 and 2.
21
by Extortion
Interferen." *rffice
(Title 18, United States Code, Sections 1951 and 2)
22
23
24
MELVIN D.BUNDY,
DAVID H.BUNDY,
BRIAN Do CAVALIER,
BLAINE C00PER,
GERALD A.DELEMUS,
ERIC JoPARKER,
0.SCOTT DREXLER,
RICHARD RoLOVELIEN,
STEVEN A.STEWART,
TODD CoENGEL,
GREGORY P.BURLESON,
JOSEPH D.0'SHAUGHNESSY,
MICAH Lo McGUIRE,and
JASON Do W00DS,
Paragraphs
On or about
49
Nevada,and elsewhere,
'
CLIVEN
D.BUNDY,
RYAN
C.BUNDY,
AMMON E.BUNDY,
RYAN WoPAYNE,
MELVIN DoBUNDY,
defendants herein, aided and abetted by each other, and by others kno vn and
COUNT FOURTEEN
lll.
CLIVEN D.BUNDY,
RYAN C.BUNDY,
AMMON E.BUNDY,
RYAN WoPAYNE,
PETER ToSANTILLI,Jr.,
MELVIN D.BUNDY,
DAVID H.BUNDY,
BRIAN D.CAVALIER,
BLAINE C00PER,
GERALD A.DELEMUS,
ERIC JoPARKER,
0 SCOTT DREXLER,
RICHARD RoLOVELIEN,
STEVEN AoSTEWART,
TODD C.ENGEL,
GREGORY P.BURLESON,
JOSEPH D.0'SHAUGHNESSY,
MICAH Lo McGUIRE,and
ASON Do W00DS,
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
defendants herein, aided and abetted by each other, and by others known and
unknown to the Grand ury,did obstruct,delay and affect conllnerce,and attempt
to obstruct, delay and affect conllnerce, and the movement of articles and
COllnOdities
18, United States Code, Section 1951, in that the defendants did obtain, and
attempt to obtain, approxilnately 400 head of cattle at or near Bunkerville,
Nevada,frolln the care,custody,and possession ofthe SAC and such other federal
law enfol cement
COUNT FIFTEEN
21
22
184. On or about April 12, 2014, in the State and Federal District of
23
24
51
CLIVEN D.BUNDY,
RYAN C.BUNDY,
AMMON EoBUNDY,
RYAN W.PAYNE,
PETER ToSANTILLI,Jr
MELVIN D.BUNDY,
DA D H.BUNDY,
BRIAN Do CAVALIER,
BLAINE C00PER,
GERALD A.DELEMUS,
ERIC J.PARKER,
0 SCOTT DREXLER,
RICHARD RoLOVELIEN,
STEVEN A.STEWART,
TODD CoENGEL,
GREGORY P.BURLESON,
JOSEPH D.0'SHAUGHNESSY,
MICAH Lo McGUIRE,and
ASON Do W00DS,
defendants herein, aided and abetted by each other, and by others known and
unknown to the grand jury, did knowingly use and carry firearlns,which weFe
brandished,during and in relation to a crirne of violence for which they may be
prosecuted in a court of the United States, that is,interference with interstate
)and
2.
COUNT S TEEN
Interstate Travel in Aid of Extortion
(Title 18,United States Code,Sections 1952 and 2)
On or about and between Apl i15 and April 12,2014,in the Federal
52
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
CLIVEN DoBUNDY,
RYAN C.BUNDY,
AMMON E.BUNDY,
RYAN WoPAYNE,
PETER ToSANTILLI,Jr
MELVIN DoBUNDY,
DAVID H.BUNDY,
BRIAN Do CAVALIER,
BLAINE C00PER,
GERALD A.DELEMUS,
ERIC J.PARKER,
0 SCOTT DREXLER,
RICHARD R.LOVELIEN,
STEVEN AoSTEWART,
TODD CoENGEL,
GREGORY P.BURLESON,
JOSEPH D.0'SHAUGHNESSY,
MICAH L.McGUIRE,and
JASON Do W00DS,
,
defendants herein, aided and abetted by each other, and by others known and
evada
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5
6
7
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CLIVEN D.BUNDY,
RYAN C.BUNDy,
AMMON E.BUNDY,
RYAN WoPAYNE,
PETER ToSANTILLI,Jr
MELVIN DoBUNDY,
DAVID HoBUNDY,
BRIAN Do CAVALIER,
BLAINE C00PER,
GERALD A.DELEMUS,
ERIC J.PARKER,
0 SCOTT DREXLER,
RICHARD RoLOVELIEN,
STEVEN AoSTEWART,
TODD C.ENGEL,
GREGORY PoBURLESON,
JOSEPH D.0'SHAUGHNESSY,
MICAH Lo McGUIRE,and
JASON Do W00DS,
,
22
defendants herein, shall forfeit to the United States of America,any fil earrn Or
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alnlnunition involved in or used in any kno ving violation of Title 18, United
24
States Code, Section 924(c), or any violation of any other crilninal law of the
54
United States, Title 18, United States Code, Sections 371, 372, 111(a)(1),
115(a)(1), 1503, 1951, and 1952: any irearm or anlnlunition possessed by the
above
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12
13
14
15
16
17
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W00DS.
All pursuant to Title 18,United States Code,Section 924(d)(1)With Title
28,United States Code,Section 2461(c)and Title 18,United States Code,Sections
924(c),371,372,111(a)(1),115(a)(1),1503,1951,and 1952.
FORFEITURE ALLEGATION T
rO
of Extortion)
3.
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21
by reference for the purpose of alleging fOrfeiture pursllant to Title 18, United
22
23
Section 2461(c).
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CLIVEN D.BUNDY,
RYAN C.BUNDY,
AMMON EoBUNDY,
RYAN WoPAYNE,
PETER ToSANTILLI,Jr
MEL N D.BUNDY,
DA DH.BUNDY,
BRIAN D.CAVALIER,
BLttNE C00PER,
GERALD A.DELEMUS,
ERIC J.PARKER,
0 SCOTT DREXLER,
RICHARD RoLOVELIEN,
STE N AoSTEWART,
TODD CoENGEL,
GREGORY P.BURLESON,
JOSEPH D.0'SHAUGHNESSY,
MICAH Lo McGUIRE,and
ASON DoW00DS,
,
defendants herein, shall forfeit to the United States of America, any firearln or
alnlnunition intended to be used in any crilne of violence,Title 18,United States
Code, Sections 371, 372, 111(a)(1), 115(a)(1), 924(c), 1503, 1951, and 1952: any
lited to
SCOTT DREXLER,RICHARD
A11
pursuant to Title 18, United states code, section 924(dx1), (2)(c), and
(3)(A) with Title 28, Unitecl States Code, Section 2461(c) and
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5
6
7
8
"i"T,Til'#"13#iffi#x,,:;:"',1:Lt.,?lsratesand
5. The allegations contained in Counts One, Seven, and Eight of this
Superseding Criminal Indictment are hereby re-alleged and incorporated herein
by reference for the purpose of alleging forfeiture pursuant to Title 18, United
States Code, Section 981(a)(1)(C) with Title 28, United States Code, Section
10
2a61G).
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6. Upon conviction
CLIVEN D.BUNDY,
RYAN C.BUNDY,
AMMON E.BUNDY,
RYAN I PAYNE,
PETER ToSANTILLI,Jr
MELVIN DoBUNDY,
DAVID H.BUNDY,
BRIAN Do CAVALIER,
BLAINE C00PER,
GERALD A.DELEMUS,
ERIC JoPARKER,
0 SCOTT DREXLER,
RICHARD RoLOVELIEN,
STEVEN AoSTEWART,
TODD C,ENGEL,
GREGORY P.BURLESON,
JOSEPH D.0'SHAUGHNESSY,
MICAH LoM[cGUIRE,and
ASON Do WOODS,
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One,
defendants herein, shall forfeit to the United. States of America, any property, real
Title
defined.
criminal forfeiture money judgment, including, but not limited to, at least
in Title 18, United States Code, Sections 1956(cX7)(D), or Title 18, United
$3,000,000
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10
ll
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13
t4
7. If any property
Title
a.
b.
c.
d.
e.
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without difficulty.
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it is the intent of the United States of America, pursuant to Title 21, United
20
States Code, Section 853(p), to seek forfeiture of any properties of the defendants
2l
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23
Cr"rrrency.
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in United
States
AIl pursuant to Title 18, United States Code, Section 981(aX1XC) with Title
28, United States Code, Section 246L(c);
and 115(a)(1); and Title 21, United States Code, Section 853(p).
Title
by reference for the purpose of alieging forfeiture pursuant to Title 18, United
States Cocle, Section 981(a)(1)(C) with Title 28, United States Code, Section
2a67@).
9. Upon conviction of any of the felony offenses charged in Counts One and
CLIVEN D.BUNDY,
RYAN C.BUNDY,
AMMON E.BUNDY,
RYAN WoPAYNE,
PETER ToSANTILLI,Jr.,
MELVIN D.BUNDY,
DAVID H.BUNDY,
BRIAN Do CAVALIER,
BLAINE C00PER,
GERALD A.DELEMUS,
ERIC J.PARKER,
0 SCOTT DREXLER,
RICHARD RoLOVELIEN,
STEVEN A.STEWART,
TODD CoENGEL,
GREGORY P.BURLESON,
OSEPH D.0'SHAUGHNESSY,
MICAH Lo MIcGUIRE,and
ASON
Do W00DS,
59
defendants herein, shall forfeit to the United States of America, anyproperty, real
or.
Titie
least g3,000,000 in United States Currency, including any and aII cattle on the
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10
ll
10. If any property subject to forfeiture purslrant to Title 18, United States
Code, Section 981(a)(1)(C) with
t2
a.
b.
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t4
has been placed beyond the jurisdiction of the court;
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16
t7
without difficulty;
l8
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20
States Code, Section 853(p), to seek forfeiture of any properties of the defendants
2l
for the
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property listed above and the in, personarri critninai forfeiture money jr"rdgment
23
incltrding, but not lirnited to, at least $3,000,000 in Unitecl States Currenc5,.
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5
6
7
8
9
10
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12
13
14
15
16
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12. Upon conviction of any of the felony offenses charged in Counts One,
Thirteen,Fourteen,and Sixteen of thiS Superseding Crilninal lndictIIlent,
CLIVEN DoBUNDY,
RYAN C.BUNDY,
AMMON E.BUNDY,
RYAN WoPAYNE,
PETER ToSANTILLI,Jr.,
MEL N D.BUNDY,
DAVID H.BUNDY,
BRIAN Do CAVALIER,
BLAINE C00PER,
GERALD A.DELEMUS,
ERIC J.PARKER,
0.SCOTT DRELER,
RICHARD RoLOVELIEN,
STEVEN AoSTEWART,
TODD CoENGEL,
GREGORY P.BURLESON,
JOSEPH D 0'SHAUGHNESSY,
MICAH Lo McGUIRE,and
JASON Do W00DS,
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61
defendants herein, shall forfeit to the United States of America, any property, real
Title
18, United States Code, Sections 1951 and 1952 ancl Nevada Revised Statute
ZOS.B20, specifi.ed
Title
Code,
forfeiture money judgment, including, but not limited to, at Least $3,000,000 in
United States Currency, including any and all cattle on the Bunkerviile Allotment
9
10
13. If any property subject to forfeiture pursuant to Title 18, United States
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t2
l4
a.
b.
c.
d.
e.
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t6
t7
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without difficulty;
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it is the intent of the United States of America, pursuant to Title 21, United
21
States Code, Section 853(p), to seek forfeiture of any properties of the defendants
22
for the ploperty listed above and the i,n personcr.rn criminal forfeiture
money
23
in United
States
24
Currency.
62
United
States Code, Section 2461(c); Title 18, United States Code, Sections
,Section 853o).
DATED:this
A TRUE BILL:
day Of March,2016.
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DANIEL G.BO
United Sta
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NW.
CHOLAS D.DICKINSON
NADIA J.AHMED
ERIN M.CREEGAN
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