Case: 16-72275, 09/26/2016, ID: 10136700, DktEntry: 3, Page 1 of 12

CASE NO. 16-72275

IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

CLIVEN D. BUNDY
Petitioner
v.
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEVADA
Respondent

From the United States District Court For the District of Nevada
The Honorable Gloria Navarro, Presiding
Case No. 2:16-CR-00046-GMN-PAL-1

EMERGENCY NOTICE CONCERNING LOCAL CRIMINAL DEFENSE

COUNSEL JOEL HANSENS MOTION AND INTENTION TO
WITHDRAW IN LOWER COURT PROCEEDING AND RENEWED
REQUEST FOR THIS COURT TO ISSUE EXPEDITED DECISION ON
PETITIONERS WRIT OF MANDAMUS

Larry Klayman
Klayman Law Firm
2020 Pennsylvania Avenue, NW
Suite 800
Washington, DC, 20006
Email: leklayman@gmail.com
Tel: 310-595-0800
Counsel for Petitioner
Attorney for Petitioner-Defendant Cliven D. Bundy
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September 26, 2016

CORPORATE DISCLOSURE STATEMENT
The Petitioner-Defendant Cliven D. Bundy is a natural person and is not an
officer, director, or majority shareholder of any publicly traded corporation. Mr.
Bundy operates a private ranching business. There is no parent corporation or
publicly-held corporation that owns more than ten percent of its stock, or any of
the stock.

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CERTIFICATE AS TO NAMED PARTIES AND INTERESTED PARTIES

Petitioner certifies pursuant to Circuit Rule 28-2.1 that:
A.

Parties - Petitioner
1)

B.

Cliven D. Bundy is a natural person

Parties - Respondent
1) The Honorable Gloria Navarro
2) U.S. District Court for the District of Nevada

C.

Interested Parties Participating

Although there are 19 defendants in the case being prosecuted together, the

present matter concerns the legal defense team for only Cliven D. Bundy.
Therefore, there are no other interested persons to identify for this specific matter.
D.

Amicus Curiae
The Petitioner is not aware of any amicus curiae participating.

E.

Related Cases
Cliven Bundy has also filed an appeal here from the District Court's

detention order in Appeal No. 16-10264.

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EMERGENCY NOTICE CONCERNING LOCAL CRIMINAL DEFENSE

COUNSEL JOEL HANSENS MOTION AND INTENTION TO
WITHDRAW IN LOWER COURT PROCEEDING AND RENEWED
REQUEST FOR THIS COURT TO ISSUE EXPEDITED DECISION ON
PETITIONERS WRIT OF MANDAMUS
Petitioner, Cliven Bundy, by and through the undersigned counsel, hereby
puts this honorable Court on notice that Petitioners one remaining counsel in the
criminal prosecution below has moved to withdraw for health reasons. Attached
hereto as Exhibit A is Joel F. Hansen, Esq.s Motion to Withdraw. Contrary to Mr.
Hansens statement in the Motion to Withdraw, Petitioner has not retained
alternative counsel, as current withdrawing local counsel suggests might occur,
since Petitioner cannot afford it. Nearly all of his sons are in prison, wrongfully
charged with crimes, and Petitioners ranch is thus in dire straights financially and
otherwise.
It thus incumbent that this Court rule immediately that the undersigned
counsel should be granted pro hac vice status, so Petitioner can have at least one
counsel to defend him. Previously, Petitioner's asked, pursuant to Circuit Rule 2712, for expedited treatment. Moreover, it has now been eighty-two (82) days since
Petitioners Emergency Motion to Expedite Petition for Writ of Mandamus
pursuant to Circuit Rule 27-12 has been filed.
Accordingly, Petitioner respectfully request a decision on his emergency
writ at this time. Pretrial dates are approaching rapidly, with trial set for only a few

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months away. Petitioner needs counsel to avoid losing his due process and other
constitutional rights, which would cause additional severe damage to him in a case
that could potentially result in his life imprisonment.
Dated: September 26, 2016

Respectfully Submitted,

___/s/ Larry Klayman, Esq.__

Larry Klayman
Klayman Law Firm
D.C. Bar No.: 334581
2020 Pennsylvania Avenue, NW
Suite 800
Washington, DC, 20006
Email: leklayman@gmail.com
Tel: 310-595-0800
Attorney for Petitioner and Member
of This Court

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CERTIFICATE OF SERVICE
I hereby certify that I electronically filed the foregoing with the Clerk of the
Court for the United States Court of Appeals for the Ninth Circuit by using the
appellate CM/ECF system on September 26, 2016. I certify that all participants in
the case are registered CM/ECF users and that service will be accomplished by the
appellate CM/ECF system.

___/s/ Larry Klayman, Esq.__

Larry Klayman

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EXHIBIT A

CaseCase:
2:16-cr-00046-GMN-PAL
16-72275, 09/26/2016,Document
ID: 10136700,
675 DktEntry:
Filed 09/23/16
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ID: 10136700,
675 DktEntry:
Filed 09/23/16
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Case
Case:
2:16-cr-00046-GMN-PAL
16-72275, 09/26/2016,Document
ID: 10136700,
675 DktEntry:
Filed 09/23/16
3, PagePage
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Case
Case:
2:16-cr-00046-GMN-PAL
16-72275, 09/26/2016,Document
ID: 10136700,
675 DktEntry:
Filed 09/23/16
3, PagePage
11 of412
of 5

Case
Case:
2:16-cr-00046-GMN-PAL
16-72275, 09/26/2016,Document
ID: 10136700,
675 DktEntry:
Filed 09/23/16
3, PagePage
12 of512
of 5