Case 2:16-cr-00046-GMN-PAL Document 680 Filed 09/26/16 Page 1 of 3

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ANGELA H. DOWS, ESQ.

PREMIER LEGAL GROUP
Nevada State Bar No. 010339
1333 North Buffalo Drive, Suite 210
Las Vegas, Nevada 89128
Telephone: (702) 794-4411
Facsimile: (702) 794-4421
E-Mail: adows@premierlegalgroup.com
Standby Counsel for Ryan C. Bundy

UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
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UNITED STATES OF AMERICA,

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Plaintiff,
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v.
RYAN C. BUNDY,
Defendant.

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2:16-cr-00046-GMN-PAL

DEFENDANT RYAN C. BUNDYS

MOTION TO JOIN IN PETER
SANTILLIS MOTION TO
CONTINUE CASE MANAGEMENT
RULE 12 MOTIONS AND NOTICES
DEADLINE BY 30 DAYS (Doc No. 672)

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Defendant RYAN C. BUNDY, by and through his standby counsel, Angela H. Dows,

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Esq., hereby joins in Defendant Peter Santillis Motion to Continue Case Management Rule 12

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Motions1 Deadlines by 30 Days (See Doc. No. 672). Instant counsel was specifically authorized

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to file the instant pleading through a telephone conference with Ryan C. Bundy on Friday,

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September 23, 2016 at approximately 8:03 p.m.

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This instant joinder is being filed as an accommodation to Ryan C. Bundy, as this Court

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is aware Mr. Ryan Bundy is in the middle of a federal jury trial in the District of Oregon. (United
States v. Bundy, et al., Case No. 3:16-cr-00051-BR). The instant joinder also incorporates all
arguments made by Defendant Santilli, with the following additional items: (1) but for the

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October 3, 2016 is the current deadline for pretrial motions and notices under Rule 12 and Local Rule
12(1)(b). It does not appear that Defendant Santilli intended to limit his request to only pretrial motions,
and is also requesting a 30-day extension of the deadline for notices of defense.

Case 2:16-cr-00046-GMN-PAL Document 680 Filed 09/26/16 Page 2 of 3

federal trial taking place in Oregon, Mr. Ryan C. Bundy would have had the ability to prepare

and file the instant joinder, and (2) but for the federal trial taking place in Oregon, Mr. Ryan C.

Bundy would have potentially had the time to prepare and file pretrial motions, notices of

defense and/or otherwise effectively prepare for his defense according to Constitutional

standards in the instant case.

Dated this 26th day of September, 2016.

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Respectfully submitted,
/s/ Angela H. Dows
ANGELA H. DOWS, ESQ.
1333 N. Buffalo Drive, Suite 210
Las Vegas, Nevada 89128
Standby counsel for Defendant Ryan C. Bundy

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Case 2:16-cr-00046-GMN-PAL Document 680 Filed 09/26/16 Page 3 of 3

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CERTIFICATE OF SERVICE
The undersigned hereby affirms that a copy of the foregoing:

DEFENDANT RYAN C. BUNDYS MOTION TO JOIN IN PETER SANTILLIS

MOTION TO CONTINUE CASE MANAGEMENT
RULE 12 MOTIONS AND NOTICES DEADLINE BY 30 DAYS (Doc No. 672)

has been served on all counsel of record via electronic transmission, pursuant to local Order.

DATED this 26th day of September, 2016.

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___/s/_____________________
ANGELA H. DOWS, ESQ.

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