Case 2:16-cr-00046-GMN-PAL Document 2936 Filed 12/01/17 Page 1 of 4

1
2
3
4
5
6
7
8

STEVEN W. MYHRE
Acting United States Attorney
District of Nevada
Nevada Bar No. 9635
NADIA J. AHMED
DANIEL R. SCHIESS
Assistant United States Attorneys
ERIN M. CREEGAN
Special Assistant United States Attorney
501 Las Vegas Blvd. South, Suite 1100
Las Vegas, Nevada 89101
(702) 388-6336
steven.myhre@usdoj.gov
nadia.ahmed@usdoj.gov
erin.creegan@usdoj.gov
dan.schiess@usdoj.gov
Representing the United States of America

9

UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

10
11

UNITED STATES OF AMERICA,

12
13
14
15
16
17

Plaintiff,
v.
DAVE H. BUNDY,
MEL D. BUNDY,
JOSEPH O’SHAUGHNESSY, and
JASON WOODS.

2:16-CR-00046-GMN-PAL
STIPULATION
PRETRIAL
DEFENDANTS

REGARDING
RELEASE
OF

Defendant.

18
19

The parties, through undersigned counsel, hereby submit this Stipulation

20

Regarding Pretrial Release of Defendants requesting that the Court release

21

Defendants Dave Bundy, Mel Bundy, Joseph O’Shaughnessy, and Jason Woods on

22

pretrial release conditions as stated below.

23
24

 Case 2:16-cr-00046-GMN-PAL Document 2936 Filed 12/01/17 Page 2 of 4

1

Defendants have been in custody since March 2016. Pursuant to the Court’s

2

Order, they are scheduled to proceed to trial thirty (30) days following the

3

conclusion of the current trial.

4

defendants Cliven Bundy, Ammon Bundy and Ryan Payne from custody with

5

conditions under the supervision of the Pretrial Services Office. Given the length

6

of time before defendants Dave Bundy, Mel Bundy, O’Shaughnessy and Woods will

7

be able to proceed to trial, the parties request that the Court release these

8

defendants under supervision by the Pretrial Services Office on conditions.

On November 29, 2017, the Court released

9

To the extent that the Court agrees to release these defendants on conditions,

10

the parties jointly request that the following conditions be imposed in addition to

11
12
13
14
15

any conditions deemed appropriate by the Court and the Pretrial Services Office:
1. The defendant shall not violate any federal, state or local law.
2. The defendant shall immediately advise the United States Pretrial Services
Office for the District of Nevada (“Pretrial Services”), the Court, defense
counsel, and the U.S. Attorney in writing before changing address or
telephone number.

16

3. The defendant must appear in court as required.

17

4. The defendant shall report to Pretrial Services as directed.

18

5. The defendant shall submit to location monitoring as deemed appropriate
by Pretrial Services.

19
20
21
22
23

6. The defendant shall remain at the address approved by Pretrial Services
between the hours of 7 pm and 7 am, except to attend, religious services,
medical appointments, meetings with counsel, employment, court
appearances, or as otherwise directed by the Court.
7. The defendant shall actively seek and/or maintain employment and notify
Pretrial Services before making any change in employment.

24
2

 Case 2:16-cr-00046-GMN-PAL Document 2936 Filed 12/01/17 Page 3 of 4

1
2
3
4
5
6
7

8. The defendant shall surrender any passport to Pretrial Services and will
not obtain any passport or other travel documents.
9. The defendant shall have no contact with any co-defendants named in the
Superseding Indictment except in the presence of his attorney and for the
purposes of preparing for future proceedings involving this case.
10. The defendant shall have no contact with a person listed as a witness on
the Government’s Witness List filed in this case, except in the presence of
counsel.
DATED this 1st day of December, 2017.
Respectfully,

8

STEVEN W. MYHRE
Acting United States Attorney

9
10

/s/ Steven W. Myhre
____________________________
NADIA J. AHMED
DANIEL R. SCHIESS
Assistant United States Attorneys
ERIN M. CREEGAN
Special Assistant United States Attorney
Attorneys for the United States

11
12
13
14
15
16
17

/s/ Lance A. Maningo

/s/ Lucas J. Gaffney

LANCE A. MANINGO
Counsel for David H. Bundy

LUCAS J. GAFFNEY
Counsel for Melvin D. Bundy

18
19
20
21

/s/ Andrea L. Luem

/s/ Kristine M. Kuzemka

ANDREA L. LUEM
Counsel for Joseph O’Shaughnessy

KRISTINE M. KUZEMKA
Counsel for Jason D. Woods

22
23
24
3

 Case 2:16-cr-00046-GMN-PAL Document 2936 Filed 12/01/17 Page 4 of 4

CERTIFICATE OF SERVICE

1
2

I certify that I am an employee of the United States Attorney’s Office. A copy

3

of the foregoing STIPULATION REGARDING PRETRIAL RELEASE OF

4

DEFENDANTS was served upon counsel of record, via Electronic Case Filing

5

(ECF).

6

DATED this 1st day of December, 2017.

7
8
9
10

/s/ Steven W. Myhre
______________________________
STEVEN W. MYHRE
Acting United States Attorney

11
12
13
14
15
16
17
18
19
20
21
22
23
24
4