Case 3:16-cr-00051-BR

Document 1388-1

Filed 10/04/16

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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON
PORTLAND DIVISION

UNITED STATES,



)

Plaintiff,




)







)
v.






)

No 3:16-cr-00051-BR-5







)

[Affidavit Verified]
RYAN BUNDY




)
Defendant.



)
_________________________________________________________)

[Affidavit] of bundy, ryan c

BEFORE ME, the undersigned authority, appeared bundy, ryan c, and after being duly sworn
deposes and says the following:
1. That I am bundy, ryan c; and,
2. That I am an approximately 44 years of age, and have lived on the land near what is believed
to be the land commonly referred to as the state of Nevada; and, That I was arrested on
January 26th 2016 for the charges of 1) Conspiracy; and 2) Aiding and Abetting among other
things. and,
3. That I do not understand the nature of the charges against my person by the United States
Government; and,
4. That I am currently detained at MULTNOMAH COUNTY DETENTION CENTER, in Portland,
Oregon; and,
5. That I am unable to obtain information from the United States Government regarding
disclosures, Brady and Giglio information which is lawfully due; and,
6. That I have filed approximately (15) fifteen motions for discovery to obtain Disclosures,
Brady, Giglio and other applicable discovery information on September 07, 2016 which is
prior to the commencement of trial; and,
7. That the United States Government filed a response in opposition ECF No.1309 on
September 20th 2016 and stated that the government had either complied with Bundy's
requests or that Bundy's requests were untimely; or Bundy had not met the threshold for
showing why he needed the information
8. That the U.S District Attorney Billy Williams did not cite to where the government had

Case 3:16-cr-00051-BR

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complied in any purported discovery they allege they've complied with.

9. That the U.S. District Attorney Billy Williams did not reference any page numbers, bates
stamps or otherwise unique identifier of the documents which they allege in a conclusory
fashion were turned over in accordance with Fed. R. Cr. P Rule 16.
10. That I, (bundy, ryan c), was allowed to view an iPad while being detained in the
MULTNOMAH COUNTY DETENTION CENTER, in Portland, Oregon
11. That the iPad contained 259,128,000 documents which were brought to me for my
inspection for an unreasonable time period.
12. That the 259,128,000 documents were not organized and my stand-by counsel did not have
them organized for my review where I could ascertain or extract any meaning from the
electronic medium.
13. That I am not technologically experienced and I do not know how to proficiently utilize an
iPad nor could I make sense of any content presented to me on said medium by Lisa Ludwig
(stand-by counsel).
14. That I communicated with Lisa Ludwig that I was unable to analysis or otherwise prepare
any defense based on this method of presenting 259,128,000 documents for my review
during an approximate (1) one-hour review.
15. That I was not allowed to retain any hard copies of said discovery and I do not believe that
my paralegals have access to any of the discovery documents to assist me in the preparation
of a defense.
THAT, I, bundy, ryan c, attest and affirm that I have personal knowledge of the foregoing statements
and that they are truthful to the best of my knowledge and belief.
FURTHER bundy, ryan c SAYETH NAUGHT

Respectfully submitted,
/s/ryan c bundy
______________________________
ryan c of the bundy society
Date: October 3rd, 2016

Case 3:16-cr-00051-BR

Document 1388-1

Filed 10/04/16

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 3rd 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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