Bundy Indictment
Bundy Indictment
Bundy Indictment
Document 58
Filed 02/03/16
Page 1 of 3
Fit.m}3FEB'1612:181.JSOC-oo>
UNDER SEAL
UNITED STATES DISTRICT COURT
DISTRICT OF OREGON
PORTLAND DIVISION
3:16-CR-0
005/-,l} A-
v.
AMMON BUNDY,
JON RITZHEIMER,
JOSEPH O'SHAUGHNESSY,
RYAN PAYNE,
RYAN BUNDY,
BRIAN CAVALIER,
SHAWNA COX,
PETER SANTILLI,
JASON PATRICK,
DUANE LEO EHMER,
DYLAN ANDERSON,
SEAN ANDERSON,
DAVID LEE FRY,
JEFF WAYNE BANTA,
SANDRA LYNN PFEIFER ANDERSON, and
KENNETH MEDENBACH,
INDICTMENT
18 u.s.c. 372
UNDER SEAL
Defendants.
Case 3:16-cr-00051-AA
Document 58
Filed 02/03/16
Page 2 of 3
conspire and agree together and with each other and with persons known and unknown to the
Grand Jury to prevent by force, intimidation, and threats, officers and employees of the United
States Fish and Wildlife Service, an agency within the Department of the Interior, from
discharging the duties of their office at the Malheur National Wildlife Refuge, in violation of
Title 18, United States Code, Section 372.
In furtherance of the conspiracy and to effect the illegal objects thereof, one or more of
the defendants and one or more of the conspirators performed the following overt acts in the
District of Oregon and elsewhere, including but not limited to the following:
a.
Oregon, to warn the Hamey County sheriff of "extreme civil unrest" if certain demands
were not met.
b.
Malheur National Wildlife Refuge by force while using and carrying firearms.
c.
and carried firearms on the premises of the Malheur National Wildlife Refuge and
prevented federal officials from performing their official duties by force, threats and
intimidation.
d.
leave the Malheur National Wildlife Refuge and allow federal officials to return to their
official duties.
Indictment
Page2
Case 3:16-cr-00051-AA
e.
Document 58
Filed 02/03/16
Page 3 of 3
violence against anybody who attempted to remove them from the Malheur National
Wildlife Refuge.
f.
recruited and encouraged other individuals, known and unknown to the grand jury, in
person and through social media and other means of communication, to participate and
assist in the above-described conspiracy.
g.
defendants and conspirators traveled to Harney County, Oregon, to intimidate and coerce
the population of Harney County, Oregon, in order to effectuate the goals of the
conspiracy.
Dated this
""S
Presented by:
BILLY J. WILLIAMS
~ETHAN D. KNIGHT
GEOFFREY A. BARROW
Assistant United States Attorneys
Indictment
Page3