Case 2:16-cr-00046-GMN-PAL Document 833-3 Filed 10/10/16 Page 1 of 3

EXHIBIT C
(Keith Gordons Declaration Page)

EXHIBIT C
(Keith Gordons Declaration Page)

Case 2:16-cr-00046-GMN-PAL Document 833-3 Filed 10/10/16 Page 2 of 3

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DANIEL J. HILL, ESQ.

NV Bar # 12773
WOLF, RIFKIN, SHAPIRO,
SCHULMAN & RABKIN LLP
3556 East Russell Road, 2nd Floor
Las Vegas, Nevada 89120
Tel: (702) 341-5200
Fax: (702) 341-5300
DHill@wrslawyers.com
Attorney for Defendant Ammon E. Bundy

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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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vs.
AMMON E. BUNDY, et al.,

CASE NO.: 2:16-cr-00046-GMN-PAL

DECLARATION OF KEITH GORDON
IN SUPPORT OF DEFENDANT
AMMON E. BUNDYS MOTION TO
DISMISS THE INDICTMENT

Defendants.

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DECLARATION OF KEITH GORDON

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I, Keith Gordon, under penalty of perjury, hereby declare as follows:

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1.

I am over eighteen years of age, and I have personal knowledge of the facts set forth

20 herein, except as to those stated on information and belief and, as to those, I am informed and believe
21 them to be true. If called upon to testify before this Court I would do so to the same effect.
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2.

I am a licensed private investigator, and have been retained by Ammon Bundys counsel

23 to investigate the above-captioned case.

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3.

On August 18, 2016, at the direction of Ammon Bundys counsel, I traveled to

25 Bunkerville, Nevada to review, scan, and photograph the contents of various dumpsters left behind by
26 the Bureau of Land Management (BLM) after they abandoned their impoundment operations on
27 April 12, 2014.
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4.

On information and belief, the dumpsters were empty when Virgin Valley Disposal

Case 2:16-cr-00046-GMN-PAL Document 833-3 Filed 10/10/16 Page 3 of 3

provided
provided them to the BLM
2014.
lll.M in
in April of
o{'2014.
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On information
belief'. therefore,
infbrmation and
and belief,
therelbre. all
all contents recovered
recovered from
fiorn the dumpsters on April

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12, 2014 were deposited there

Bl.M or
present for
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there by agents of the BLM
or other
other federal
federal agencies
agencies present
fbr the
the

impoundment
impoundment operation.
operation.
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6.

infbrmation and
On information
the contents recovered
dumpsters have
atrd belief,
belicf . all
all of
ol-thc
recovercd from
sr"rh.icct clunipstcrs
liom the subject

been carcfully
carefully and securely
stored under
lock and
kcy since
since April
April of
in the
securely stored
undcr lock
and key
of 2012,
201 2.and
remain in
the same
sanre state
statc
and remain

as when they were recovered.

recovered.
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7.

tt
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I took
took the
the photographs attached
attached to
to Ammon
Ammon Bundy's Motion
Motion to Dismiss
Disrriiss the
Indictmerrt
thc Indictment

as Exhibit A. They
shredded documents
1'hey accurately depict multiple bags of
of'shreddcd
on information
documcnts that,
that. on
intbrnration and
ancl

l0 belief,
were recovered from
2014.
beliel" werc
fiom the
thc dumpsters
12,2014.
durnpsters used by the BLM on April 12,
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tl.

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I scanned
scanned the document attached to Ammon Bundy's
Bundy's Motion
Motion to
Dismiss the
lndictmcnt
to Dismiss
thc Indictment

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"Free Speech
as
Irxhibit B. ItIt accurately
as Exhibit
accurately depicts
depicts aa memorandum
memorandum titled
titled "Free
Speech vs.
vs. Impeding
hnpcding Operations,"
Opcrations.'"

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which,
dumpsters used
infbrmation and belief,
recovcred from
fi'onr the durnpstcrs
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which. on information
belicf. was recovered
usecl by the BI,M
[]l.M on
orr April
April 12,

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2014.

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9.

As a licensed
liccnsed private investigator
investigator and
and former
lbrmer law
law enforcement
enforccment officer.
oflrcer. II neither deduced
decluccd

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nor inferred
inf'erred any indications
photographcd have been
indications that any of the documents or items I scanned or photographed
becn

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tampered
1?.2014.
2014.
tanrpered with since their recovery
recovery from
l'rom the subject
sub.icct dumpsters on April 12.

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periury under
Under
penalties of perjury
under the laws
Under penalties
laws of the United
[Jnited States of America
Americtr and the State of
ol'

l9 Nevada.
declare that the foregoing
Nevada" I declare
lbregoing is true and correct to my
my own
own knowledge,
knowledge. except as to those
thclsc
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infbrmation and belief,

mattcrs II believe
matters
matters stated on information
bcliel" and that as to such matters
helicvc to be
be true.
truc.

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,.)

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2s
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DATED
DA'I-[1D this
rhis

2016.
october 2016.
Wray day of October