Case 3:16-cv-01057-MA

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BILLY J. WILLIAMS, OSB #901366

United States Attorney
District of Oregon
KATHERINE C. LORENZ
Katie.Lorenz@usdoj.gov
Assistant United States Attorney
United States Attorneys Office
1000 SW Third Avenue, Suite 600
Portland, Oregon 97204-2902
Telephone: 503-727-1000
Facsimile: 503-727-1117
Attorneys for the United States of America

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON
PORTLAND DIVISION

UNITED STATES OF AMERICA,

Plaintiff,
v.

3:16-CV-01057-MA
COMPLAINT IN REM FOR
FORFEITURE

50 FIREARMS AND ASSORTED

AMMUNITION, in rem,
Defendants.

Plaintiff, United States of America, by Billy J. Williams, United States

Attorney for the District of Oregon, and Katherine C. Lorenz, Assistant United
States Attorney, for its complaint in rem for forfeiture, alleges:

Complaint in rem for Forfeiture

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I.
This Court has subject matter jurisdiction, in rem jurisdiction, and venue
pursuant to 18 U.S.C. 924; 28 U.S.C. 1345, 1355, 1356, and 1395; and 19 U.S.C.
1610.
II.
Defendants, in rem, 50 Firearms and Assorted Ammunition, further
described in the attached Exhibit A (the Declaration of Katherine D. Armstrong,
Special Agent at the Federal Bureau of Investigation), are now and during the
pendency of this action will be within the jurisdiction of this Court.
III.
Defendants, in rem, 50 Firearms and Assorted Ammunition, were involved in
or used in a conspiracy to impede officers of the United States, in knowing and
willful violation of 18 U.S.C. 372, and are therefore forfeitable to the United
States pursuant to 18 U.S.C. 924(d), as more particularly set forth in the attached
declaration of Special Agent Katherine D. Armstrong, marked as Exhibit A, which
is attached and incorporated herein by this reference.
WHEREFORE, plaintiff, United States of America, prays that due process
issue to enforce the forfeiture of defendants, in rem, 50 Firearms and Assorted
Ammunition; that due notice be given to all interested persons to appear and show
cause why forfeiture of these defendants, in rem, should not be decreed; that due
proceedings be had thereon; that these defendants be forfeited to the United States;
that the plaintiff United States of America be awarded its costs and disbursements
Complaint in rem for Forfeiture

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incurred in this action, and that plaintiff have such other and further relief as is
just and equitable.
Respectfully submitted this 10th day of June 2016.
BILLY J. WILLIAMS
United States Attorney
s/ Katie Lorenz___________
KATHERINE C. LORENZ
Assistant United States Attorney

Complaint in rem for Forfeiture

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VERIFICATION
I, Katherine D. Armstrong, declare, under penalty of perjury, pursuant to the
provisions of 28 U.S.C. 1746, that I am a Special Agent with the Federal Bureau of
Investigation (FBI), and that the foregoing Complaint in rem for Forfeiture is made
on the basis of information officially furnished, and upon the basis of such
information the Complaint in rem for Forfeiture is true as I verily believe.

s/ Katherine D. Armstrong
KATHERINE D. ARMSTRONG
Special Agent
Federal Bureau of Investigation

Complaint in rem for Forfeiture

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DECLARATION OF SPECIAL AGENT KATHERINE D. ARMSTRONG

I, Katherine D. Armstrong, do hereby declare:
Training and Experience
1.

I am a Special Agent (SA) of the Federal Bureau of Investigation (FBI) and

have been so employed for approximately two (2) years. I am currently assigned to
the FBIs Portland Division and am part of the violent and organized crime squad.
In 2014, I successfully completed twenty-one (21) weeks of training at the FBI
Academy located in Quantico, Virginia. During that time, I was taught the use and
practical application of various investigative techniques that Federal law
enforcement officers are allowed to employ.
2.

In addition to my formalized training in violations of the law at the FBI

Academy, I have also acquired knowledge and information pertaining to violations

of federal law from numerous other sources, including: formal and informal training
by other law enforcement officers and investigators, informants, and my
participation in other investigations. Prior to joining the FBI, I was a prosecutor
with the Philadelphia District Attorneys Office for approximately two-and-a-half
years and briefly worked in the private sector as a civil litigator. I attended law
school at Temple University in Philadelphia, Pennsylvania, and have been admitted
to practice law since October 2010.
Purpose of Declaration and Background of the Investigation
3.

This declaration is made in support of the Complaint in rem for the forfeiture

of 50 firearms and assorted ammunition described below. The facts set forth in this
Declaration of Katherine D. Armstrong

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declaration are based on the following: my own personal knowledge; knowledge

obtained from other individuals during my participation in this investigation,
including other law enforcement officers; my review of records related to this
investigation; communications with others who have knowledge of the events and
circumstances described herein; and information gained through my training and
experience. Because this declaration is submitted for the limited purpose of
establishing probable cause in support of the forfeiture of the defendants in rem, it
does not set forth each and every fact that I or others have learned during the
course of this investigation.
4.

Federal law provides that it is unlawful under 18 U.S.C. 372 to conspire to

impede officers of the United States from discharging their duties by force,
intimidation, or threat. Under 18 U.S.C. 924(d), any firearm or ammunition
involved in or used in any violation of any criminal law of the United States is
subject to seizure and forfeiture. As described below, each of the defendants, in
rem, was involved in or used in a conspiracy to impede officers of the United States,
in knowing and willful violation of 18 U.S.C. 372, and is therefore forfeitable to
the United States pursuant to 18 U.S.C. 924(d).
5.

On January 2, 2016, several hundred unidentified individuals participated in

a protest in Burns, Oregon, related to the resentencing of local ranchers Steven and
Dwight Hammond following their criminal convictions by a jury. Following the
protest, certain now-indicted conspirators entered the Malheur National Wildlife
Refuge (MNWR), blocked the entrance, and began an unlawful armed occupation of
Declaration of Katherine D. Armstrong

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several buildings within the MNWR. The MNWR and all buildings located thereon
are federal property and facilities located in Harney County in the District of
Oregon. The armed occupation of the MNWR was continuous and ongoing from
January 2, 2016, until the occupation ended in the morning hours of February 11,
2016.
6.

At the time of the takeover of MNWR, those involved in the initial entry and

occupation (occupiers) carried out the initial clearing of buildings on MNWR while
most were armed with rifles. The individuals cleared the buildings in a tactical
manner while armed. Occupiers also moved MNWR vehicles into positions that
blocked entrances to the MNWR. Occupiers moved heavy equipment in front of at
least one entrance to the MNWR as well.
7.

The MNWR is staffed by employees of the United States Fish and Wildlife

Service (USFWS). As a result of the armed occupation of the MNWR by the known
conspirators and others, employees of the USFWS who work at the MNWR were
prevented from reporting to work during the occupation because of threats of
violence posed by the defendants and others occupying the property. Sixteen (16)
federal employees work at the MNWR, including one federal law enforcement officer
and a volunteer coordinator who lived on the Refuge before the armed takeover and
works in the visitor center. The MNWR was closed on January 2, 2016, and portions
of the facility that occupiers used remain closed to the public as of the date of this
declaration. Employees were allowed to return to work at the MNWR on or about
February 29, 2016.
Declaration of Katherine D. Armstrong

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8.

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Due to the presence of armed individuals occupying MNWR, and also upon

learning that some of the occupiers supporters were still in the Burns area, the
Bureau of Land Management (BLM) made the decision to close the Burns District
Office, located at 28910 Highway 20 West, Hines, Oregon, 97738. The BLM office
was closed during the entire time the MNWR was unlawfully occupied. This action
was taken out of concern for the safety of the approximately 80 employees who work
there.
9.

Throughout the armed occupation, many occupiers were photographed by

local, state, and national news media outlets carrying guns on their person.
Occupiers were photographed carrying both long guns and pistols in clearly visible
holsters. The carrying of these weapons was intended as a show of force and
intimidation.
10.

Individuals who participated in the armed occupation of MNWR made

statements concerning the possession of firearms --- including the need for
additional firearms to be brought by additional supporters to MNWR --- so that the
demands they made would be taken seriously, so they could defend themselves if
law enforcement officers engaged with them, and because they were conducting
security patrols of MNWR. Additionally, several armed occupiers stated they would
not leave without their demands being met, and were willing to die at MNWR. For
example, occupier Jon Ritzheimer stated on several social media websites that he
would not be arrested and, I want to die a free man. Ritzheimer made further
video-taped statements such as I am one hundred percent willing to lay my life
Declaration of Katherine D. Armstrong

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down to fight against tyranny in this country, and while addressing his family, said
that no matter what, just know that I stood for something, dont let it be in vain.
Occupiers Blaine Cooper and Jon Ritzheimer posted a video to YouTube on January
4, 2016. In the video, Ritzheimer stated, we need you to get here and stand with us.
More than anything. Whether you are armed or unarmed, you get up here.
11.

In public meetings preceding the takeover, both Ryan Payne and Ammon

Bundy, characterized by other occupiers as leaders in the armed occupation, stated

that the intent of their effort was to remove the federal government from Harney
County and to prevent the Hammonds from spending one more night in jail. During
the first few days of the armed occupation, indicted co-conspirator Pete Santilli used
his YouTube Channel to provide live-stream coverage of the events in Burns,
Oregon. During one of these live-stream sessions late at night on January 5, 2016,
Joseph OShaughnessy was interviewed and stated, Im right now in the process of
trying to set up a constitutional security protection force to make sure that these
federal agents and these law enforcement dont just come in here like cowboys,
thats we have to prevent that
12.

During an interview on a national news morning show, which was filmed

during the occupation, Ammon Bundy stated the occupiers were armed because We
are serious about being here. Were serious about defending our rights, and we are
serious about getting some things straightened out. When asked if he anticipated
the occupation would lead to violence, Bundy responded, Only if the government
wants to take it there.
Declaration of Katherine D. Armstrong

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13.

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On January 5, 2016, in a video taken by indicted co-conspirator Pete Santilli

and posted to YouTube, Jon Ritzheimer stated, last word we got is theyre headed
out here, in reference to the belief the armed occupiers held, that they were going
to be raided by the federal government. Ritzheimer goes on to state, theyre headed
out here, uh, so we are trying to plan and maintain a defensive posture. In the
video, Ritzheimer can be seen carrying what appears to be, based on my training,
experience, and knowledge of firearms, an AR-15 style rifle with a sling.
14.

The armed occupiers would often hold press briefings on MNWR grounds.

During a press briefing videotaped on January 3, 2016, Ammon Bundy stated, We

are calling people to come out here and stand, and We need you to bring your
arms and we need you to come to the Malheur National Wildlife Refuge. At one
point during the armed occupation, environmental activists attended to hold
counter protests. During one of these press briefings and counter protests, an
environmental activist was accused by indicted co-conspirator Pete Santilli of being
an undercover FBI agent. I reviewed an interview of the activist accused of being an
undercover agent, and learned that when the accusation was levied, the crowd
became ugly, at which point the activist and a friend who also attended left the
scene as they feared for their safety.
15.

According to numerous reports and interviews I read concerning this matter,

armed occupiers conducted security patrols and performed guard duty both in a
watchtower overseeing the MNWR and at front and back entrances to the MNWR.
Patrol and guard duties typically required occupiers to carry either a sidearm or
Declaration of Katherine D. Armstrong

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have access to a long gun. Ryan Payne, along with other unknown unindicted coconspirators, provided guidance to other occupiers concerning tactics, and occupiers
were placed into teams to split up guard shift and patrol duties. When not on
duty, some teams would practice patrol movements. There was firearm training at
the refuge as well, though not all occupiers participated.
16.

On January 26, 2016, at approximately 4:25 p.m., the FBI and the Oregon

State Police began an enforcement action to take into federal custody individuals
involved in the armed occupation of the Malheur National Wildlife Refuge. Shots
were fired during the arrest, and LaVoy Finicum was killed. Ryan Bundy was
injured. The following individuals were taken into custody: Ammon Bundy, Ryan
Payne, Ryan Bundy, Brian Cavalier, and Shawna Cox. During separate events in
the evening of January 26, 2016, Joseph OShaughnessy and Peter Santilli were
taken into custody as well. Jon Ritzheimer was taken into custody in Arizona on the
same day.
17.

On January 26, 2016, Ammon Bundy, Ritzheimer, OShaughnessy, Payne,

Ryan Bundy, Cavalier, Cox, and Santilli were charged by Criminal Complaint with
the felony crime of Conspiracy to Impede Officers of the United States from
discharging their official duties through the use of force, intimidation, or threats, in
violation of Title 18, United States Code, Section 372.
18.

On January 28, 2016, Duane Ehmer, Dylan Anderson, and Jason Patrick

were charged by Criminal Complaint with the felony crime of Conspiracy to Impede
Officers of the United States from discharging their official duties through the use
Declaration of Katherine D. Armstrong

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of force, intimidation, or threats, in violation of Title 18, United States Code,

Section 372.
19.

As described above, the individuals initially charged by criminal complaint

and later indicted by a grand jury, most of whom were armed, worked together with
many additional unindicted actors, both known and unknown, to control federal
property while refusing to leave, intending to impede and prevent by force the
federal officials who worked on and used that property from performing their official
duties. The use and display of firearms was integral to this conspiracy.
Seized Firearms and Ammunition Subject to Forfeiture
20.

After the death of Finicum and arrest of Ammon Bundy and other leaders of

the occupation on January 26, 2016, remaining occupiers of MNWR began to leave
the refuge. By the early morning hours of January 27, 2016, law enforcement
officers had established a series of checkpoints at major roads in and out of MNWR.
Prior to the checkpoints being established, several vehicles left the refuge. Some of
these occupiers may have left with weapons, as they left prior to a later law
enforcement instruction to occupiers to leave MNWR without their weapons.
21.

Several occupiers refused to leave MNWR grounds by January 28, and

established an encampment area outside on the west side of MNWR. These

individuals engaged in lengthy negotiations with FBI. As mentioned above, it was
communicated to these final occupiers that they were to leave MNWR without their
weapons.

Declaration of Katherine D. Armstrong

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22.

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The occupations ended on February 11, 2016 when the last occupier, David

Fry, surrendered to FBI agents at MNWR.

23.

A search of MNWR commenced on February 12, 2016 at approximately 8:00

a.m. The search ended on February 23, 2016 at approximately 2:38 p.m. Consent to
search all MNWR facilities and property was given by Federal Wildlife Officer John
Megan.
24.

Throughout the armed occupation, occupiers were seen driving government

vehicles. These vehicles were also searched by FBI agents. Consent to search those
vehicles was also given by Federal Wildlife Officer John Megan.
25.

During the search of MNWR facilities and property, 14 privately owned

vehicles were determined to be present on MWNR property. On February 19, 2016,

a search warrant was signed and agents began to search those vehicles.
26.

In all, a total of 23 structures, nine (9) exterior locations, 14 privately-owned

vehicles, and numerous government-owned vehicles were searched.

27.

During the search, the following ammunition was seized from the MNWR

guard tower (Building 21):

Item Group No.
33

28.

Item Description
One (1) round of ammunition with 04, 75 markings

The following ammunition was seized from the RV Park Day Room (Building

15):
///
Declaration of Katherine D. Armstrong

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Item Group No.

34

29.

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Item Description
Sixteen (16) .223 caliber ammunition rounds, packaged in
container found separately

35

Two (2) magazines each with large caliber bullets, no serial

number visible

36

One (1) box of Remington brand buckshot, 12-gauge,

containing (5) shotshells

The following ammunition was seized from the three-bedroom bunkhouse

(Building 17) located on MNWR:

Item Group No.
37

Item Description
One (1) unspent rifle ammunition round, 7.62 x 54

38

One (1) unspent rifle ammunition round, 7.62 x 54

39

One (1) box of Red Army Standard 7.62 x 54R cartridges,

containing nineteen (19) unspent cartridges

40

One (1) box of Red Army Standard 7.62 x 54R cartridges,

contains six (6) unspent cartridges

41

Three (3) boxes of ZQ Ammunition, 7.62 x 51mm rifle

cartridges, with two (2) full boxes containing twenty (20)
rounds and one (1) box containing four (4) rounds, all unspent

42

Thirty-five (35) rifle rounds, unspent, unknown caliber

43

One (1) unspent 7.62 x 54 ammunition round

44

One (1) Smith & Wesson .40 caliber ammunition round

45

One (1) full box of AR Tactical 22 Long Rifle .22 caliber

ammunition rounds

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The following ammunition was seized from the maintenance shop (Building

12) located on MNWR:

Item Group No.
46

31.

Item Description
Forty-one (41) unspent rifle rounds, .223 caliber

47

One (1) unspent rifle round, .223 caliber

48

One (1) unspent rifle round, .223 caliber

49

One (1) 12-gauge shotgun shell, red and gold in color

50

One (1) unspent rifle round, .233 caliber

51

One (1) unspent rifle round, .223 caliber

52

One (1) rifle magazine

The following ammunition was seized from the new fire shop (Building 19)

located on MNWR:
Item Group No.
53

32.

Item Description
Three (3) magazines containing ammunition

54

Four (4) shotgun shells

55

Six (6) shotgun shells

56

One (1) 7.62 round

57

One (1) loaded magazine

The armed occupiers who stayed on the refuge after January 28, 2016,

created an outdoor encampment on the west side of MNWR. The encampment was
located adjacent to a trench and when searched between the dates of February 15
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and February 19, 2016, contained abandoned property, government-owned vehicles,

and privately-owned vehicles. The following firearms and ammunition were seized
from the west encampment:
Item Group No.
58

Item Description
Defense Procurement Manufacturing Services (DPMS), model
Panther, .223 caliber, serial number FH218222, with shoulder
stock, strap, bipod, tactical grip and Vortex Strikefire scope

59

Anderson Manufacturing, model AM15, multi-caliber, serial

number 15120075, with shoulder stock and sight

60

Remington Arms Company, Inc., model 740, serial number

18173, with strap

61

Tula (Russian) rifle, model SKS, .762 caliber, serial number

255, with attached bayonet

62

Izhmash (IMEZ) - RA, model Saiga, .223 caliber, serial number

H09163414

63

The Rifle Specialist, model PRS-15, 5.56mm, serial number

PRS 10001112, with scope

64

Smith & Wesson, model 10, .38 caliber, serial number

D320584

65

Hi-Point, model C9, 9mm pistol, serial number P1301748

66

One (1) white cardboard box sealed and said to contain 250 12gauge shotgun shells

67

One (1) white cardboard box sealed and said to contain 1,000
5.56mm cartridges

68

One (1) green plastic Cabelas-brand ammunition box sealed

and said to contain 900 7.62mm cartridges

69

One (1) green metal ammunition box sealed and said to

contain 100 30-30 cartridges

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70

One (1) green plastic ammunition box sealed and said to

contain 670 5.56 cartridges

71

Ammunition described as: 10 shotgun shells; Excess of 350

7.62x39 cartridges

72

Ammunition described as: 20 - 22.250 Rem; 27-7.62x39, 700 .22; 8 - 30-30; 40 - 7.62x54; 40 - 45 Auto; 48-9mm

73
74

Ninety (90) shotgun shells, three (3) .223 cartridges, one (1) .45
auto cartridge, and one (1) 30-30
Twenty-seven (27) .223 cartridges

75

Two (2) magazines with cartridges

76

Seven (7) 7.62x39 cartridges

77

Six (6) 6.38 caliber cartridges

78

One (1) magazine containing forty-five (45) 5.56 cartridges

79

One (1) magazine and seventeen (17) cartridges

80

Three (3) magazines (empty) and 156 live rounds, 9mm Luger

81

Two (2) magazines and fifty-nine (59) cartridges

82

Two (2) magazines containing 5.56 mm cartridges

83

One (1) magazine containing cartridges

84

Cartridges: Ten (10) 30-06, seventy-six (76) 300 Winchester

and ninety-six (96) 7.62

85

Sun City Machinery Co., 12-gauge shotgun, model Stevens

320, serial number 134744C

86

Tennessee Arms, model TNARMS-15, 556 NATO caliber,

serial number 1527410852, with shoulder stock

87

Amadeo Rossi, model type not provided, 38 special, serial

number D254978

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88

Benelli, model Nova, 12-gauge, serial number Z492773, with

strap

89

Smith & Wesson, model 686, .357 caliber, serial number

AWT7091

90

Sig Sauer, model P220, .45 caliber, serial number G171401

91

Remington Arms Company, model 783, .308 caliber, serial

number RM93637F, with strap, scope, and bipod

92

Sturm Ruger, model Mini 14, 5.56 NATO caliber, serial

number 583-11135, with shoulder stock

93

Ruger, model Mini 14, .223 caliber, serial number 187-05936,

with strap bearing the name Sage

94

Winchester 12-gauge shotgun, model 1300 Defender, serial

number L3624942, with external shotgun shell holder

95

Mossberg, model 500A, 12-gauge, serial number U348536

96

Taurus, model PT740 Slim, .40 caliber, serial number

SGT34329

97

Jimenz Arms, model J.A. 380, .380 caliber, serial number

093877

98

Five (5) shotgun shells

99

One (1) magazine containing Remington .223 caliber rounds

and one (1) loose, .223 caliber round

100

Five (5) .38 Special rounds

101

One (1) Tapco magazine containing 7.62 rounds

102

Five (5) shotgun shells

103

Six (6) .357 caliber rounds

104

Three (3) magazines containing .45 caliber rounds and one (1)
loose, .45 caliber round

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105

One (1) magazine containing .308 caliber rounds and one (1)
loose, .308 caliber round

106

Two (2) magazine containing .223 caliber rounds

107

One (1) magazine containing .223 caliber rounds

108

One (1) magazine containing .223 caliber rounds and one (1)
loose, .223 caliber round

109

Fourteen (14) shotgun shells

110

One (1) magazine containing 40 caliber rounds

111

One (1) magazine containing 380 rounds

112

One (1) white cardboard box sealed and said to contain: 50

(fifty) 12-gauge shells; 15 (fifteen) .308 rounds; 300 (three
hundred) rounds Remington 22 Thunderbolt; 500 (five
hundred) .223 rounds contained in 8 (eight) magazines; 200
(two hundred) .45 rounds in one (1) blue bag; 25 (twenty-five)
.40 rounds in one (1) blue bag; 25 (twenty-five) 9mm rounds
contained in 3 (three) magazines

113

Ammunition described as: 6 - 12-gauge shotgun shells; 4 - 7.62

cartridges; and 2 - .45 caliber cartridges

114

Sturm Ruger, model Mini 14 Ranch Rifle, .223 rem caliber,

serial number 197-14924, with strap and scope

115

Hi-Point, model C9, 9mm, serial number P1668416

116

Remington, model 870 Express Magnum, 12-gauge, serial

number A369528M

117

Ruger, model Single Six, .22 caliber, serial number 268-20582

118

Ruger, model Speed Six, .357 caliber, serial number 162-20762

119

Tula Russian SKS rifle, 7.62x39mm, Made in Russia Imported Vermont, serial number 3K8550

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120

IMBEL/Springfield Armory, model 1911A1, .45 caliber, serial

number N523326

121

Rifle, Manufacturer Yugoslavia, model 59/66A1, .762 caliber,

serial number G200828, with strap, flashlight, and bipod

122

Harrington & Richardson/New England Firearms Gardner, 12gauge, serial number NK268865, with strap

123

Steyr, (Importer PW Arms), Made in Russia, model

unknown, 30 7.62 x 54R caliber, serial number RMN0126828,
with strap

124

Savage Arms, model 116, .300 Winchester Magnum caliber,

serial number H585352, with scope

125

Winchester, model 94A, .30 Winchester caliber, serial number

5311759

126

One (1) white cardboard box sealed and said to contain: 900
(nine hundred) .223 cartridges; 500 (five hundred) .45 caliber
rounds; 400 (four hundred) 7.62 caliber rounds; 250 (two
hundred-fifty) 9mm rounds; 50 (fifty) .22 caliber rounds; 50
(fifty) .357 caliber rounds

127

One (1) white cardboard box sealed and said to contain: 150
(one hundred-fifty) .223 rounds; 50 (fifty) 22-250 rounds; 50
(fifty) .357 rounds; 60 (sixty) 7.62 rounds; 25 (twenty-five) 3030 rounds; 25 (twenty-five) .38 rounds; 15 (fifteen) .45 rounds

128

One (1) 12-gauge shotgun shell

129

Nine (9) shotgun shells

130

Six (6) .22 caliber cartridges

131

Five (5) cartridges

132

Seven (7) 30.30 cartridges

133

Two (2) magazines containing 45 caliber cartridges

Declaration of Katherine D. Armstrong

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134

Two (2) magazines containing .223 cartridges

135

One (1) magazine containing thirty-nine (39) 7.62 cartridges

In addition to creating encampments, the armed occupiers dug several

trenches. Investigators referred to these trenches in reports as Trench 1, Trench 2,

and Trench 3. Trench 1 was located on the west side of MNWR, adjacent to the west
encampment and MNWR parking lot. Trench 2 was located adjacent to the guard
tower. Trench 3 was determined to primarily be a garbage pit, located in the
proximity of MNWR RV pads, adjacent to a large gravel pile and MNWR burn area.
The following ammunition was seized from Trench 2:
Item Group No.
136

34.

Item Description
One (1) rifle round, type not provided

137

One (1) shotgun shell

138

One (1) shotgun shell

The following ammunition was seized from a fire truck located near the east

blockade on MNWR:
Item Group No.
139
35.

Item Description
One (1) rifle magazine

The following ammunition was seized from the fire bunkhouse (Building 20)

on MNWR:
Item Group No.
140

Item Description
Two (2) rounds of 7.62 x 39 Tulammo (live)

Declaration of Katherine D. Armstrong

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141

One (1) round of 7.62 x 39 Tulammo (live)

142

One (1) 12-gauge made in USA black color shotgun shell (live)

143

Twenty-Three (23) rounds of Fiocci USA 223 Remington (live)

144

One (1) pistol magazine with thirty (30) round capacity, black
in color; loaded with unknown number of live ammunition
with red tip

145

Seven (7) rounds LC15 greentip

146

Two (2) bullets [one (1) LC14 + one (1) LC08]

147

One (1) round 22 Hornet (live)

148

Three (3) rounds 7.62 x 39 (live)

149

Three (3) bullets LC14

150

One (1) 10 x bullet holder GGG Assy 11010483

151

One (1) bullet LC15 (live)

152

One (1) White Centurio 2 3/4" 12-gauge shotgun shell

153

One (1) bullet Hornady 223 REM broken tip

154

One (1) 2 x bullet holder GGGASSY 11010483

155

One (1) blank bullet, Shelton LPS 845LC

156

One (1) bullet RP 38 SPL

157

One (1) Mech-gar 18-round magazine with 18 rounds

Beretta written on it

158

One (1) bullet LC14

159

One (1) round of Winchester 45 auto ammunition

160

One (1) Live FC1614 round of ammunition

Declaration of Katherine D. Armstrong

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161

One (1) shotgun shell, 00 Buck

162

One (1) box of Remington 308 WIN x twenty (20) live rounds
of ammunition

163

Five (5) live rounds of GFL 9 Corto 03 ammunition

164

Forty-one (41) live rounds of PPU 223 REM ammunition

165

Eight (8) Winchester 12-gauge shotgun shells: seven (7) buck

and one (1) slug

166

Two (2) boxes of Federal 45 auto ammunition, 100 live rounds

167

Four (4) live rounds of ammunition: three (3) FC2414 and one
(1) LC15

168

Two (2) live rounds: one (1) LC12 and one (1) .223 Remington

169

One (1) empty Glock 9mm thirty-one (31) round magazine with
spring and bottom plate

170

One (1) round OEV 02 M80 7.62 ammunition

171

One (1) live round of Remington ammunition

172

Two (2) live Winchester 12-gauge shotgun shells, red in color

173

One (1) live round of FC 308 Winchester ammunition

174

Two (2) live rounds of ammunition: one (1) FC1614 and one (1)
FC0714

175

One (1) live round of Winchester 9mm Luger ammunition

176

One (1) live round of LC15 ammunition

177

One (1) live round of b x n 54 ammunition

Declaration of Katherine D. Armstrong

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The following ammunition was seized from MNWR employee Carla

Burnsides office (Building 7A) on MNWR. Ms. Burnside had not been in her office
since the occupation began and was present at the time of the search during which
the following items were seized, none of which belonged to her.
Item Group No.
178

Item Description
One (1) unspent round of ammunition, caliber not visible

179

Five (5) .45 caliber ammunition rounds, unspent, found

together

180

Twenty-five (25) Winchester 12-gauge shotgun shells

181

Two (2) black magazines with Gale Benson scratched on

bottoms, full of large ammunition rounds

182

Three (3) .45 caliber ammunition rounds, unspent

183

One (1) box of American Eagle brand 5.56 x 45 mm, green

tipped, unspent ammunition rounds, box ripped with large
quantity of rounds spilled on floor

184

Approximately eighty-four (84) unspent rifle ammunition

rounds, with green tips found in gray bag

185

Twenty (20) .38 caliber ammunition rounds, unspent, found

together inside white bottle

186

One (1) Sturm, Ruger & Company, Inc. magazine (empty),

black in color, inside plastic bag and one (1) Ruger magazine
(empty), black in color, inside original packaging

187

One (1) white container labeled 45 Auto, full of unspent

ammunition rounds

188

Five (5) boxes of Winchester 12-gauge shotgun shells, all boxes

full

Declaration of Katherine D. Armstrong

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The following ammunition was seized from MNWR employee Linda Becks

office (Building 7B) on MNWR. Ms. Beck had not been in her office since the
occupation began. Ms. Beck assisted the evidence response teams in determining
what items were property of the MNWR. The following items were seized, none of
which belonged to Ms. Beck:
Item Group No.
189

Item Description
Bulk live ammunition Wolf WPA .223 Remington

190

One (1) box .38 Special 147gr Total Metal Jacket and one (1)
loose round

191

.38 Special 158gr jacketed hollow point bullets

192

One (1) green box containing loose, 7.62 ammunition

193

Eight (8) .357 live rounds

194

.223 bullets in brown paper wrapping

195

Four (4) rounds of R-P .38 Special

196

Four (4) 12-gauge shotgun shells (3 green shells and 1 red

shell)

197

Twenty (20) rounds CBC brass .357 Magnum

198

Thirty-four (34) boxes of 12-gauge 00 Buckshot shells and five

(5) additional loose shells

199

Two (2) black metal ammunition magazines with bullets

200

One (1) box American Eagle 5.56 X .45mm grain Full Metal
Jacket bullets

201

One (1) box .223 Remington HV 50GRS V-Max polymer tip

bullets

Declaration of Katherine D. Armstrong

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202

One (1) black, high capacity magazine containing bullets

203

One (1) box .45 auto 230gr FMJ Tul ammunition

204

One (1) black, high capacity magazine containing bullets

205

One (1) bag of loose 9mm Luger bullets

206

One (1) .45 Colt WW bullet

207

One (1) box 12-gauge, 2 3/4 inch, 1 1/8 ounce, 8-shot, target
load shotgun shells

208

One (1) partial box Hornady Zombie Max green tip 40 S&W
165gr bullets

209

Two (2) gray-colored metal ammunition magazines

210

Two (2) boxes MKE ZQ ammunition 7.62X51MM

211

Two (2) boxes Ultramax Remanufactured .223 Remington

ammunition

212

One (1) box of Fiocchi ammunition 22-250 Remington and one

(1) box of Remington High Performance Rifle 22-250
Remington ammunition

213

Four (4) boxes of Fiocitti ammunition .223 Remington, two (2)

boxes Hornady ammunition .223 Remington, twelve (12)
stripper clips containing .223 ammunition

214

One (1) box 12-gauge, 2 3/4 Dram Eq., 1 1/8 ounce, 8-shot
Target Load, Federal Ammunition

215

One (1) Wolf .223 Remington live round

///
///

Declaration of Katherine D. Armstrong

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The following ammunition was seized from the boat launch area at MNWR,

located approximately 1.5 miles northeast of the MNWR RV parking area:

Item Group No.
216

Item Description
Seventeen (17) 7.62 caliber shell casings

217

Thirty (30) 7.62 caliber shell casings

218

Forty-two (42) 9mm caliber shell casings

219

Seven (7) .40 caliber shell casings

220

Ten (10) .45 caliber shell casings

221

One (1) live 7.62 caliber round

222

Ten (10) 7.62 caliber shell casings

223

Six (6) .308 caliber shell casings

224

Six (6) .223 caliber shell casings

225

Thirty-one (31) 9mm caliber shell casings

226

Thirty-four (34) .45 caliber shell casings

227

Five (5) 7.62 caliber shell casings

228

Sixty-eight (68) .223 caliber shell casings

229

One hundred fifty-eight (158) 9mm caliber shell casings

230

Thirty-eight (38) .40 caliber shell casings

231

Four (4) .45 caliber shell casings

232

Fourteen (14) 7.62 caliber shell casings

233

Seventy-six (76) 7.62 caliber shell casings

234

Six hundred eighty-four (684) .223 caliber shell casings

235

Thirty-eight (38) 9mm shell casings

236

Eighteen (18) .40 caliber shell casings

237

Sixteen (16) .45 caliber shell casings

238

Twenty-four (24) 7.62x39 shell casings

239

Three (3) live .223 rounds

Declaration of Katherine D. Armstrong

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240

Two hundred ninety-two (292) .223 shell casings

241

One green metal ammunition box with KPK inscribed on

exterior, containing three hundred forty-two (342) rounds of
.308 ammunition, and seven (7) Pmag clips and one
magazine in packaging

The following ammunition was seized during a ground sweep of MNWR. It

was located near MNWRs fence line near the field house, on both sides of the fence
line. The fence separated MNWR from a private residence, described as a one-story
green house with white external propane tank:
Item Group No.
242

40.

Item Description
Four (4) .223 caliber shell casings and two (2) 7.62 caliber shell
casings

The following ammunition was seized from the north side of the MNWR main

service road, adjacent to a heavy equipment storage area and two shipping
containers:
Item Group No.
243

41.

Item Description
One (1) .223 caliber shell casing

As mentioned above, during the search of MNWR facilities and property,

fourteen privately-owned vehicles were determined to be present on MNWR

property. On February 19, 2016, a search warrant was signed and agents began to
search those vehicles.
42.

The following firearms and ammunition were seized from a Dodge Ram truck

with Texas license plate BMK2664, VIN 1D7HA8D432S243452:

Declaration of Katherine D. Armstrong

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Item Group No.

244

43.

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Item Description
One (1) Intra-tech, model TEC-DC9, 9mm Luger pistol, serial
number D064235, with strap

245

One (1) metal ammunition box, army green in color, containing

an excess of two hundred (200) rounds of 9mm ammunition

246

One (1) magazine containing 9mm live ammunition

The following ammunition was seized from a Chevrolet Silverado truck with

Arizona license plate CE82218, VIN 1GCHK23D77F165753:

Item Group No.
247
248

44.

Item Description
Seven (7) .223 caliber ammunition rounds, all unspent
One (1) army green metal canister with Federal Ammunition
label, containing 420 rounds of 5.56 x 45mm unspent
ammunition

The following ammunition was seized from a Chrysler Town and Country

minivan with Utah license plate X186TL, VIN 2A4GP64L36R708639:

Item Group No.
249
250

45.

Item Description
One (1) .223 caliber ammunition, unspent
One (1) box of Remington pistol and revolver cartridges,
containing fifty (50) 9mm rounds

The following ammunition was seized from a Chevrolet Silverado Z71 4x4

pick-up truck with Montana license plate 307605A, VIN 1GC4K0C87BF126174:

Item Group No.
251
252

Item Description
One (1) .45 caliber live ammunition
Fifty-Eight (58) spent .223 casings and one (1) spent 7.62, M80
casing

Declaration of Katherine D. Armstrong

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46.

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253

One (1) evidence sealed box said to contain one (1) green
ammunition can with bag of rifle rounds marked LC 13 on
the headstamps

254

Seven (7) .223 rifle casings and two (2) MKE 14 casings

Just prior to the execution of search warrants at MNWR, on February 10,

2016, Jason Blomgren, an indicted co-conspirator who posted videos of himself at

MNWR with other occupiers and performing guard duty, was arrested in Mesquite,
Nevada. During a post-arrest interview, Blomgren stated that after Finicum was
killed, Blomgren was concerned the federal government would try to murder him.
To protect himself, he began to carry a Smith & Wesson .40 caliber pistol at all
times. Blomgren received the gun from a fellow occupier Nathan Pieters when they
were at MNWR. Blomgren met Pieters at MNWR. At the time of his arrest,
Blomgren was armed with a Smith & Wesson .40 caliber handgun. This was the
same gun Blomgren had received from Pieters. The following firearm and
ammunition were seized from Blomgren at the time of his arrest:
Item Group No.
255

Item Description
One (1) Smith & Wesson .40 caliber pistol, model SD40VE,
serial number HER5993

256

Three (3) magazines each containing fourteen (14) rounds

47.

Indicted co-conspirator Eric Flores was arrested on February 10, 2016, and

gave a post-arrest interview on February 11, 2016. Flores stated he brought almost
all of his guns to MNWR, including one CZ Rami .40 caliber pistol. Flores handed
Declaration of Katherine D. Armstrong

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out his weapons to other occupiers at MNWR. Flores gave fellow occupier Darryl
Thorn two weapons, a Ruger 5.56mm (AR-15) and his CZ Rami pistol. Flores
believed at the time of his arrest that Thorn was still in possession of his Ruger 5.56
and CZ Rami. Thorn wanted to keep them in the event somebody needed a weapon
to loan, or possibly buy.
48.

On February 11, 2016, indicted co-conspirator Darryl Thorn was arrested in

the lobby of the Super 8 Motel located in Redmond, Oregon. Thorn had been
previously photographed at MNWR during the course of the armed occupation,
often armed with a rifle. Thorn had been shown performing guard tower duty in a
video produced by VICE News while the armed occupation was still ongoing. Upon
Thorns arrest, agents conducted a search of the hotel room he had been staying in
with his girlfriend. Thorns girlfriend rented the hotel room in her name. The
following firearm matching the description Flores gave of the pistol he gave Thorn
was seized from the hotel room:
Item Group No.
257

49.

Item Description
One (1) CZ-USA pistol, .40 caliber, model 2075, serial
number A751986

As mentioned above, on February 10, 2016, indicted co-conspirator Eric

Flores was arrested at his residence in Tulalip, Washington. Flores had been
previously photographed at MNWR carrying a rifle. Flores was also photographed
in the guard tower while the armed occupation was ongoing. Upon arrest, Flores
gave consent to seize several firearms in his possession. These firearms were
discovered in Flores bedroom. During a post-arrest interview, Flores admitted
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travelling to MNWR multiple times and eventually bringing all his firearms with
him to MNWR except for an SKS rifle. Flores loaned out some of his firearms to
individuals occupying MNWR who did not have any. Flores was shown a
photograph taken on MNWR grounds during the armed occupation. Flores was
armed with an AR-15 pistol and Darryl Thorn was holding an AR-15 with drum
magazine. Flores identified himself and further advised the AR-15 pistol and drum
magazine shown in the photograph are the same ones agents retrieved from his
bedroom in his home with his consent following his arrest. Flores stated he, and
others, brought weapons to MNWR to protect themselves. The following firearms
and ammunition were seized from Flores home at the time of his arrest:
Item Group No.

Item Description

258

One (1) Tennessee Arms Company AR-15 pistol, serial number

1426504512, with stabilizing brace, strap, backup sights, AR15 upper receiver and barrel and loaded AR-15 drum magazine

259

One (1) Mossberg, model 930, 12-gauge shotgun, serial number

AF128047

260

One (1) Norinco, SKS rifle, 7.62x39 caliber, serial number

25001594K, with bipod and one(1) loaded 7.62 caliber
magazine

261

Six (6) shotgun shells and one (1) shotgun part

262

One (1) metal box with seven (7) boxes of 5.56 ammunition,
each box containing three (3) 10-round clips

50.

On February 18, 2016, agents received a firearm from Tulalip Tribal Police

Department. This firearm was seized by Tulalip Tribal Police Department from
Flores cousin by consent earlier that same day. This firearm was also taken to the
Declaration of Katherine D. Armstrong

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armed occupation at MNWR by Flores. During a post-arrest interview, Flores stated

he left three AR-15 rifles, a Saiga AK, and two pistols at the MNWR when he left
the refuge. Indicted co-conspirator Darryl Thorn brought one of the AR-15 rifles to
Flores after Thorn returned to Washington State. Flores gave that rifle to his
cousin Robert Joseph as a self-defense weapon. Flores frequently loans his firearms
to others. The following firearm was seized by the Tulalip Tribal Police Department
from Flores cousin:
Item Group No.

Item Description

263

AR-15 rifle with Tennessee Arms Company LLC lower receiver

(multi-caliber) and Palmetto State Armory upper receiver
(5.56), serial 1527410940

51.

On February 11, 2016, Wesley Kjar, an indicted co-conspirator, was arrested

in Salt Lake City, Utah. Kjar was photographed at MNWR on January 6, 2016,
holding a rifle. In an article published on April 13, 2016 by VICE News, a reporter
writes he traveled from MNWR with Kjar and others, going to Utah and later
returning to MNWR to retrieve Kjars belongings before leaving again. The reporter
states Kjar collected his AR-15 from MNWR before leaving the second time. In the
same article, Kjar was photographed carrying a pistol in a holster on his hip,
standing in front of a building on MNWR grounds. Kjar also posted comments to his
Facebook page, including the statement that people needed to come to Oregon and
stand for the Ranchers and citizens of Harney county. On the day of his arrest, FBI
Special Agents conducted a vehicle search of a white Jeep Wrangler and grey race
trailer being towed by an army truck that was owned by Kjar. The following
Declaration of Katherine D. Armstrong

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firearms and ammunition were seized from the Jeep and grey trailer:
Item Group No.
264

Item Description
One (1) I.O. Inc rifle, model Sporter 15, .223 caliber, serial
number ARI00418, with light, accessory sights and magpul
grip

265

One (1) Ruger rifle, model 10/22 Takedown, .22 caliber, serial
number 826-83980, with two (2) empty magazines contained in
stock of rifle

266

One (1) Colt rifle, model SP1, .223 caliber, serial number
SP29206, with attached strap

267

One (1) DPMS rifle, model AR-15, .223 caliber, serial number
FFH044398, with attached Vortex spitfire scope

268

One (1) HS Products (Importer: Springfield) pistol, model XDM

3.8, .45 caliber, serial number MG657131

269

One (1) HS Products (Importer: Springfield) pistol, model XDS

3.3, .45 caliber, serial number S3190016

270

One (1) box containing fifteen (15) rifle magazines containing

live ammunition (.223/5.56)

271

One (1) Wal-Mart bag containing one (1) box of Remington 22

Thunderbolt ammunition, 500 rounds

272

Three (3) pistol magazines containing live ammunition (45

auto) and one (1) empty pistol magazine

273

One (1) box containing 425 loose .223 rounds live ammunition

274

One(1) green ammunition can containing 200 rounds of Blazer

.45 ammunition

275

One (1) empty rifle magazine (.22 caliber)

276

One (1) box containing one (1) clear plastic bag containing 56
spent bullet casings (.223/5.56), and seven (7) magazine covers

Declaration of Katherine D. Armstrong

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On February 11, 2016, Corey Lequieu, an indicted co-conspirator, was

arrested in Fallon, Nevada. Lequieu was photographed carrying a firearm and

driving a government ATV while on MNWR during the armed occupation. Lequieu
was also seen on video taken on January 4, 2016, during a press conference given by
Ammon Bundy. Lequieu can be seen in the background, carrying a rifle. Following
Lequieus arrest, FBI Special Agents traveled to Lequieus residence which he
shared with Debra Pope. Pope had also traveled to MNWR during the armed
occupation. Pope was asked about materials which she and Lequieu had taken from
MNWR following their participation in the armed occupation. Pope consented to
agents seizing ammunition Lequieu had taken from MNWR when they traveled
there. Pope then retrieved ammunition from the home she shared with Lequieu.
Pope advised agents the ammunition had been stored in either her room or the gun
safe in her house. Pope stated she had locked the ammunition in the gun safe and
hidden the key from Lequieu. The following ammunition was seized:
Item Group No.
277

Item Description
Seventy-nine (79) rounds of 9mm ammunition

278

526 rounds of 5.56 mm ammunition as follows: ten (1) thirtyround magazines containing 30 rounds each; one (1) twentyround magazine containing seventeen (17) rounds each; one (1)
green in color bandoleer containing 140 rounds; one (1) box
containing 30 rounds; and one (1) ziplock baggie containing 39
rounds

279

Six (6) 30-round magazines, one (1) forty-round magazine, and

one (1) ten-round magazine

280

1,500 rounds of .223 Remington ammunition

Declaration of Katherine D. Armstrong

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During their conversation with Pope, agents learned that Lequieu had

weapons located at the residence of Mary Cross, also in Fallon, Nevada. Agents
accompanied Pope to Crosss residence. Pope identified an AR-15-type rifle as the
one carried by Lequieu at MNWR. This firearm was located in the trunk of a vehicle
on the property along with another firearm. Agents seized the following items from
the trunk:
Item Group No.
281
282

54.

Item Description
One (1) Browning, model Hi-Power 9mm, serial number
245NM32652
One (1) Palmetto State Armory, model PA-15, multi-caliber,
serial number LW068295

On February 11, 2016, indicted co-conspirator Geoffrey Stanek was arrested

in Forest Grove, Oregon. Stanek was photographed at MNWR during the armed
occupation. In one of the photographs, taken by Rob Kerr for Getty Images, Stanek
is standing in a garage at MNWR with what, based on my training and experience,
appears to be a smaller model Glock handgun. Following his arrest, Stanek
consented to FBI Special Agents searching a 2000 blue Dodge Durango. Stanek
owned this vehicle and had been driving it just prior to his arrest. During the
search, the following firearm was seized:
Item Group No.
283

Item Description
One (1) Glock GMBH, 26 Gen 4, .9mm handgun, serial number
XVA150, with loaded 9-round magazine

///
Declaration of Katherine D. Armstrong

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Scott Willingham was photographed at MNWR and captured on video helping

remove government cameras from electricity poles. Willingham was later indicted
on one federal charge of theft for stealing government cameras. Prior to the
indictment, on March 16, 2016, Willingham was arrested by the Grant County
Sheriffs Office on charges of disorderly conduct. During the course of the arrest,
officers learned that Willingham was in possession of a rifle. Willingham agreed to
turn the rifle over to the Sheriffs Office. Willingham then took officers to a
residence and showed them the rifle and bullets. Willingham was interviewed after
his arrest and told investigators that prior to leaving MNWR, he took a rifle from
Ryan Paynes truck. Willingham stated the rifle belonged to Payne and Payne had it
when he was in Afghanistan. Willingham described the weapon as an FN .308 rifle.
The following firearm and ammunition was seized from Willingham by the Grant
County Sheriffs Office:

Item Group No.

284
285

Item Description
One (1) Springfield SAR-4800 Sporter rifle, serial number
SA16479, with Vortex scope, bipod, strap and five (5) empty
magazines
Two hundred twenty-three (223) rifle rounds, consisting of one
hundred seventy-nine (179) .308 Winchester rounds and fortyfour (44) 7.62mm rounds
Conclusion

56.

It is evident from the statements and actions of the armed occupiers that the

open carry, display, and talk of weapons and need to use force if confronted by
federal agents, was done for the purpose of threatening and intimidating federal
Declaration of Katherine D. Armstrong

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officials from discharging their duties. These actions were ongoing and continuous
from the beginning of the armed occupation on January 2, 2016 until the last
individual left MNWR on February 11, 2016.
57.

Given the seizure locations of all the firearms and ammunition discussed in

this declaration, the repeated observed use of firearms by occupiers described above,
the public solicitation by occupiers for additional supporters to come to MNWR and
bring firearms with them, the fact that none of the seized firearms and ammunition
are believed to belong to MNWR employees, and the post-arrest statements of
several occupiers, it is my belief that all of the firearms and ammunition described
in this declaration had been brought to or near MNWR grounds by the indicted and
unindicted occupiers prior to seizure for the purpose of impeding, intimidating, and
threatening federal officers from discharging their duties.
58.

Based on my experience as a Special Agent with the Federal Bureau of

Investigation and the circumstances described in this declaration, I have reason to

believe that the defendants, in rem, described in this declaration are subject to
seizure and forfeiture. There is probable cause to believe that each of the 50
firearms and the assorted ammunition I have described were involved in or used in
a conspiracy to impede officers of the United States in knowing and willful violation
of 18 U.S.C. 372, and are therefore forfeitable to the United States pursuant to 18
U.S.C. 924(d).
///

Declaration of Katherine D. Armstrong

EXHIBIT A PAGE 34
Complaint In Rem
FOR FORFEITURE

Case 3:16-cv-01057-MA

Document 1-1

Filed 06/10/16

Page 35 of 35

I declare under penalty of perjury that the foregoing is true and correct
pursuant to 28 U.S.C. 1746.
Executed on this 10th day of June 2016.
s/ Katherine D. Armstrong
KATHERINE D. ARMSTRONG
Special Agent
Federal Bureau of Investigation

Declaration of Katherine D. Armstrong

EXHIBIT A PAGE 35
Complaint In Rem
FOR FORFEITURE

Case 3:16-cv-01057-MA

Document 1-2

Filed 06/10/16

Page 1 of 1

CIVIL COVER SHEET

OJS 44 (Rev. 12/07)

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided
by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating
the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)

I. (a) PLAINTIFFS
United States of America

DEFENDANTS
50 Firearms and Assorted Ammunition, in rem

(b) County of Residence of First Listed Plaintiff

County of Residence of First Listed Defendant

(EXCEPT IN U.S. PLAINTIFF CASES)

Multnomah

(IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE
LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number)

Katherine C. Lorenz - United States Attorney's Office
1000 SW Third Ave., Suite 600 Portland, OR 97204
II. BASIS OF JURISDICTION (Place an X in One Box Only)

Attorneys (If Known)

III. CITIZENSHIP OF PRINCIPAL PARTIES(Place an X in One Box for Plaintiff

U.S. Government
Plaintiff

3 Federal Question
(U.S. Government Not a Party)

(For Diversity Cases Only)

PTF
Citizen of This State
1

U.S. Government
Defendant

4 Diversity

Citizen of Another State

Incorporated and Principal Place

of Business In Another State

Citizen or Subject of a
Foreign Country

Foreign Nation

(Indicate Citizenship of Parties in Item III)

IV. NATURE OF SUIT

CONTRACT

110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excl. Veterans)
153 Recovery of Overpayment
of Veterans Benefits
160 Stockholders Suits
190 Other Contract
195 Contract Product Liability
196 Franchise
REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property

V. ORIGIN
1 Original
Proceeding

DEF
1

(Place an X in One Box Only)

TORTS
PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
CIVIL RIGHTS
441 Voting
442 Employment
443 Housing/
Accommodations
444 Welfare
445 Amer. w/Disabilities Employment
446 Amer. w/Disabilities Other
440 Other Civil Rights

FORFEITURE/PENALTY

PERSONAL INJURY
362 Personal Injury Med. Malpractice
365 Personal Injury Product Liability
368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
370 Other Fraud
371 Truth in Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability
PRISONER PETITIONS
510 Motions to Vacate
Sentence
Habeas Corpus:
530 General
535 Death Penalty
540 Mandamus & Other
550 Civil Rights
555 Prison Condition

State Court

BANKRUPTCY

422 Appeal 28 USC 158

423 Withdrawal
28 USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark

SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
FEDERAL TAX SUITS
870 Taxes (U.S. Plaintiff
or Defendant)
871 IRSThird Party
26 USC 7609

OTHER STATUTES

IMMIGRATION
462 Naturalization Application
463 Habeas Corpus Alien Detainee
465 Other Immigration
Actions

400 State Reapportionment

410 Antitrust
430 Banks and Banking
450 Commerce
460 Deportation
470 Racketeer Influenced and
Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
810 Selective Service
850 Securities/Commodities/
Exchange
875 Customer Challenge
12 USC 3410
890 Other Statutory Actions
891 Agricultural Acts
892 Economic Stabilization Act
893 Environmental Matters
894 Energy Allocation Act
895 Freedom of Information
Act
900Appeal of Fee Determination
Under Equal Access
to Justice
950 Constitutionality of
State Statutes

Appeal to District

(Place an X in One Box Only)

2 Removed from

610 Agriculture
620 Other Food & Drug
625 Drug Related Seizure
of Property 21 USC 881
630 Liquor Laws
640 R.R. & Truck
650 Airline Regs.
660 Occupational
Safety/Health
690 Other
LABOR
710 Fair Labor Standards
Act
720 Labor/Mgmt. Relations
730 Labor/Mgmt.Reporting
& Disclosure Act
740 Railway Labor Act
790 Other Labor Litigation
791 Empl. Ret. Inc.
Security Act

and One Box for Defendant)

PTF
DEF
Incorporated or Principal Place
4
4
of Business In This State

3 Remanded from
Appellate Court

from
4 Reinstated or 5 Transferred
6 Multidistrict
another district
Reopened
Litigation
(specify)

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

from
7 Judge
Magistrate
Judgment

18: 372 / 18:924(d)

VI. CAUSE OF ACTION Brief description of cause:
items involved in or used in a conspiracy to impede officers of the United States
CHECK YES only if demanded in complaint:
DEMAND $
CHECK IF THIS IS A CLASS ACTION
VII. REQUESTED IN
UNDER F.R.C.P. 23
Yes
No
JURY DEMAND:
COMPLAINT:
VIII. RELATED CASE(S)
(See instructions):
JUDGE Anna J. Brown 3:16-CR-00051-BR DOCKET NUMBER Marsh 3:16-CV-00918-MA
IF ANY
DATE

SIGNATURE OF ATTORNEY OF RECORD

6/10/2016

s/Katie Lorenz

FOR OFFICE USE ONLY

RECEIPT #

AMOUNT

APPLYING IFP

Submit

JUDGE

Go

MAG. JUDGE