Case 3:16-cr-00051-BR

Document 1426

Filed 10/13/16

Page 1 of 2

Ryan Bundy, Pro Se

Inmate: Swis#795070
Multnomah County Detention Center
11540 NE Inverness Drive
Portland, OR 97220
Telephone: (503) 988-3689
Defendant

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON

UNITED STATES OF AMERICA,

) Case No. 3:16-cr-00051-BR

Plaintiff,

vs.

RYAN BUNDY, et al
Defendant

) DEFENDANT RYAN BUNDYS

OBJECTION AND RESPONSE TO THE
)
GOVERNMENTS MOTION TO QUASH
)

COMES NOW DEFENDANT RYAN BUNDY with this objection and response to the
Governments Motion to Quash subpoena of Friends of the Malheur.
THE SUBPOENA IS ENTIRELY WITHIN THE SCOPE OF F.R.CRIM.P. 17
Federal Rule of Criminal Procedure 17(c) governs the issuance of a subpoena duces tecum:
(1) In General. A subpoena may order the witness to produce any
books, papers, documents, data, or other objects the subpoena designates. The
court may direct the witness to produce the designated items in court before trial
or before they are to be offered in evidence. When the items arrive, the court
may permit the parties and their attorneys to inspect all or part of them.
(2) Quashing or Modifying the Subpoena. On motion made promptly,
the court may quash or modify the subpoena if compliance would be unreasonable
or oppressive.

Case 3:16-cr-00051-BR

Document 1426

Filed 10/13/16

Page 2 of 2

The Government falsely asserts that Defendants subpoena is designed to harass or intimidate a
witness. The Government provides no support whatsoever for this assertion. Neither does the
Government provide any authority to support its contention that the subpoena is intended only to
obtain impeachment evidence. (For that matter, the Government doesnt even provide any
authority for its proposition that subpoenas are not to be used for the purpose of discovery or to
obtain impeachment evidence).
The subpoena is entirely proper, and aimed at developing relevant, material evidence for the
defense.
Respectfully submitted this 13h day of October, 2016.

/s/ Ryan Bundy*

Pro Se Defendant

*Filed on behalf of Mr. Bundy by standby counsel Lisa J. Ludwig, OSB #953387