Case 3:16-cr-00051-BR

Document 1211

Filed 09/07/16

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AT THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON
PORTLAND DIVISION
UNITED STATES,
Plaintiff,
v.
RYAN BUNDY,
Defendant named in error.

CASE NO. 3:16-cr-00051-BR-05]

AFFIDAVIT
VERIFIED

Defendants Motion for Production and Inspection of Grand Jury Proceedings

NOW COMES THE DEFENDANT herein, and moves this Court for an Order permitting, prior
to trial or prior to the eve of trial, inspection and copying of the proceedings of the Grand Jury
that returned the above-styled indictment, and the proceedings of any Grand Juries that
considered the subject matter of this indictment. In support thereof, Defendant shows the
following:
1. Defendant believes that witnesses have testified before the Grand Jury providing testimony
relevant to the criminal charges asserted against defendant.
2. Transcripts of the witnesses Grand Jury testimony would be of great assistance in enabling
Defendant to determine with particularity the nature of the Governments charges in this case.
The indictment does not contain sufficient particulars to inform Defendant of the evidence upon
which the accusations contained therein are based.
3. If the Court should determine that immediate disclosure is inappropriate, disclosure no later
than 21 days prior to trial is suggested as a reasonable alternative.

Case 3:16-cr-00051-BR

Document 1211

Filed 09/07/16

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WHEREFORE, Defendant respectfully prays that this Court enter an order granting his motion
for pretrial production and inspection of Grand Jury proceedings, and for such other and further
relief as this Court may deem just and proper.

MEMORANDUM OF LAW
Rule 6(e)(3), Federal Rules of Criminal Procedure, permits pretrial disclosure of matters
occurring before the grand jury upon the direction of the Court in connection with any judicial
proceeding.
The district court has discretionary authority to determine whether there is a continuing need for
grand jury secrecy with regard to requests for transcripts of grand jury proceedings. Douglas Oil
Co. v. Petrol Stops Northwest, 441 U.S. 211 (1979).

Respectfully submitted,
/s/ryan c bundy
______________________________
ryan c of the bundy society
Dated: 9/7/16

Case 3:16-cr-00051-BR

Document 1211

Filed 09/07/16

Verification
I certify the foregoing is true and correct under the
penalty of perjury pursuant to 28 USC 1746 that I
am over the age of 18 years, that I have personal
knowledge of the facts stated herein, and that I am
fully competent to testify to those facts.
/s/ryan c bundy
_________________________
ryan c of the bundy society

Certificate of Service
This the 7th day of September 2016 a true and correct
copy of the foregoing was served to the court, and
opposing counsel by first-class mail or better.
/s/ryan c bundy
______________________
ryan c of the bundy society

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