Case 3:16-cr-00051-BR

Document 1333

Filed 09/23/16

Page 1 of 3

BILLY J. WILLIAMS, OSB #9013q6

United States Attorney

District of Oregon
ETHAN D. KNIGHT, OSB #992984 .
GEOFFREY A. BARROW
CRAIG J. GABRIEL, OSB #012571
Assistant United States Attorneys
ethan.kni ght@usdoj.gov
geoffrey. battow@usdoj.gov
craig.gabriel@usdoj.gov
1000 SW Third Ave., Suite 600
Portland, OR 97204-2902
Telephone: (503) 727-1000
Attorneys for United _States of America

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

UNITED STATES OF AMERICA

v.

3:16-CR-0'0051-BR-1
FACTUAL STIPULATION
REGARDING LAPTOP

AMMON BUNDY,
Defendant.

The United States of America, by Billy J. Williams, United States Attorney for the
District of Oregon, and through Ethan D. Knight, Geoffrey A. Barrow, and Craig J. Gabriel,
Assistant United States Attorneys, and defendant Ammon Bundy through his counsel, Marcus
Mumford, hereby stipulate and agree as follows:

Case 3:16-cr-00051-BR

1.

Document 1333

Filed 09/23/16

Page 2 of 3

An Apple MacBook model A1502, identified as serial number C02NDCP2G3QJ,

was seized by the Deschutes County Sheriffs Office on January 27, 2016, from the Jeep Ammon
Bundy was traveling in on January 26, 2016, when he was arrested. The Apple MacBook was
collected by the FBI from the Deschutes County Sheriffs Office, 63333 Highway 20 West, Bend,
Oregon 97701, on January 27, 2016.
2.

Thereafter, the government created two complete, exact, and accurate duplicates of

the Apple MacBook hard drive using reliable methods. One duplicate was sent to the FBI
Laboratory in Quantico, Virginia, to attempt to get into the data. The attempt was unsuccessful
and that drive was returned to FBI Portland and placed into evidence (lBl 124) . . The N01thwest
Regional Computer Forensics Laboratory has the second copy, which it is currently trying to
access using forensic techniques.
3.

The duplicates are "admissible into evidence to the same extent as the original,"

within the meaning of Fed. R. Evid. 1003.

I II
II I

Ill
Ill
II I

Ill
Ill
Ill
II I
Factual Stipulation Regarding Laptop

Page2

Case 3:16-cr-00051-BR

4.

Document 1333

Filed 09/23/16

Page 3 of 3

The duplicates, and any of their contents, may be admitted into evidence instead of

the returned hard drive, in any legal proceedings where the returned hard drive or its contents
would be admissible.
Dated this 7th day of September 2016.
Respectfully submitted,
BILLY J. WILLIAMS

IT IS SO STIPULATED.

MARCUS R. MUMFORD
Counsel for Defendant Ammon Bundy

Factual Stipulation Regarding Laptop

Page3