Case 3:17-cr-00008-JCC Document 11 Filed 02/04/17 Page 1 – 25

Defendant Marcus Mumford, through his attorney Michael Levine, respectfully moves for dismissal of all charges against the defendant for four distinct reasons. First, the charges should be dismissed in light of the outrageous government misconduct that precipitated the charges.

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Case 2:16-cr-00046-GMN-PAL Document 1436 Filed 01/27/17 Page 1 – 7

Bridge Photos Ruling ImminentCourt Gives Government 3 Days To RespondOn 27 January 2017, Parker, Drexler, and Stewart motioned to exclude from trial photos taken showing them on the NB I-15 bridge on Saturday, 12 April 2014. Their counsel argues that the opening in the jersey barrier is only 1.5 inches wide. Subsequently, no agent under the SB I-15 bridge would have been able to perceive an imminent threat from any of the three. In addition, Stewart didn’t surface in any agency reports until after photographs of the trio circulated widely in the media. The Court ruled that the Government will […]

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Case 2:16-cr-00046-GMN-PAL Document 1491 Filed 02/02/17 Page 1 – 12

DEFENDANT RYAN PAYNE’S EMERGENCY MOTION TO DISMISS AND ALTERNATIVE REQUEST FOR IMMEDIATE RELEASE OF GRAND JURY TRANSCRIPTS AND BRADY MATERIALS (Expedited hearing and treatment requested)

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Case 2:16-cr-00046-GMN-PAL Document 1492 Filed 02/02/17 Page 1 – 6

STEVEN STEWART DEFENDANT’S MOTION TO DISMISSDefendants Request Case DismissalSAC Daniel P. Love’s Ethics Violations Not Properly DisclosedSteven Stewart motioned for the dismissal of the entire case against Tier 3 Defendants. The Government has the responsibility to disseminate certain information to defendants if it will help their case. Love was the subject of an ethics inquirydetailing two events occurring in 2015. The Department of Interior’s Office of the Inspector General (OIG) found that Love’s behavior in both incidents was in serious violation of Department policies. Due to these violations and Love’s role in Bundy Ranch, the incidents described by the OIG’s report fall […]

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Case 2:16-cr-00046-GMN-PAL Document 1483 Filed 02/02/17 Page 1 – 16

Count Three DismissedDistrict of Nevada rules against 924(c)’s Residual Clause…Chief Judge Gloria Navarro dismissed Count Three of the Superseding Indictment. Her decision overruled Magistrate Judge Peggy Leen’s recommendation that the charge stay on the indictment. Count Three, known as a 924(c) “enhancement”, provides additional stiff penalties for defendants who use or carry a firearm in furtherance of a crime of violence. The underlying charge, Count Two, (Conspiracy to Impede or Injure a Federal Officer 18 USC § 372), falls into an evolving legal standard regarding “crimes of violence”. The portion of § 924(c) that applies to § 372 is void for vagueness due to recent Supreme Court […]

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Case 2:16-cr-00046-GMN-PAL Document 1463 Filed 02/01/17 Page 1 – 3

Court Protects Jurors Identities Because of Defendant’s SupportersChief Judge Gloria Navarro issued a ruling today effectively putting the jury in the upcoming Tier 3 trial under the same protective order as all of the discovery evidence. The order comes as no surprise since the case historically garners much media attention. However, it wasn’t the act of putting juror identities under protective order that gave rise to notice; it was the reason for the order that stands out as peculiar.Vocal supporters…From the ruling…The Court also notes there have been several occasions during the pendency of this case when (1) pro-Defendant demonstrators have […]

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