Case 3:16-cr-00051-BR

Document 1442-1

Filed 10/16/16

Page 1 of 2

I.

Terry Petrie, DOJ

a. Testimony
i. Terry Petrie is a DOJ lawyer. He will testify about the litigation surrounding the
impoundment orders issued in the District of Nevada on July 9, 2013 in Docket
Number 12-CV-804, and on October 8, 2013 in Docket Number 98-CV-531. He
will also describe a deposition that he took of Cliven Bundy.
b. Discovery- The filings are publically available through ECF. Nevertheless, we will
produce the significant filings for your convenience. We will also provide a copy of the
deposition Petrie took of Cliven Bundy.
c. Exhibits
i. Govt Exhibit 157 Redacted Order in 12-CV-804
ii. Govt Exhibit 158 Redacted Order in 98-CV-531

II.

Jason Curry, BLM

a. Testimony
i. Jason Curry will testify about his role in the impoundment of the cattle at
Bunkerville. He will testify consistent with his report of the event.
b. Discovery
i. Currys report has previously been disclosed at MNWR_0066439
c. Exhibits
i. We will use a demonstrative of the bridge and the wash.
Lucas McLain, HCSO
a. Testimony
i. McLain will testify that he was not present at any meeting at Ye Olde Castle on
1/2/16. Instead, he attended a law enforcement briefing at 0700 on 1/2/16. All
law enforcement officers were ordered to work with a partner at all times.
McLains partner was HCSO Dan Jenkins.
b. Discovery
i. We will produce a copy of a CAD report documenting McLains activities on
1/2/16/
c. Exhibits
i. None.
Judge Grasty
a. Testimony
i. Judge Grasty will testify regarding community sentiment regarding the
occupation. He will testify that large numbers of people descended on Harney
County in January of 2016 and that they openly carried weapons in a manner
that was unusual for Burns and Harney County. Judge Grasty publically asked
Ammon Bundy and the occupiers to leave on January 19, 2016. He will explain
why he denied the request for a permit to use the fairgrounds
b. Discovery
i. None
c. Exhibits
i. Govt Exhibit 659

III.

IV.

Case 3:16-cr-00051-BR

V.

Chad Karges
a. Testimony

Document 1442-1

Filed 10/16/16

Page 2 of 2

1. Chad Karges will testify that no USFWS employees went to the refuge
headquarters during the occupation.

b. Discovery
i. None
c. Exhibits
i. None