This is The Sentencing Memorandum for the previously Shared 91 Page Exhibit A B. Factual Background The underlying facts of defendant’s case are accurately set forth in paragraphs 14 through 36 of the Presentence Report (hereafter “PSR”). 1. Pre-Occupation Defendant Payne has a long history of opposing the authority of the federal government. In 2013, Payne cofounded Operation Mutual Aid (OMA). The purpose of OMA was to create a network of militiamen to respond to situations involving conflict with the government and law enforcement. In 2014, OMA issued a formal call to action for militia forces to respond to Bunkerville, Nevada, … Continue reading Case 3:16-cr-00051-BR Document 2519 Filed 02/21/18 Page 1 of 14