Gov’t’s Memo in Support of Its Motion for PT Detention Page 2

The United States, by and through undersigned counsel, respectfully submits

this Memorandum in Support of its Motion for Pretrial Detention pursuant to The

Bail Reform Act, Title 18, United States Code, S ection 3142. As explained h erein,

the government seeks the continued pretrial detention of defendant Cliven Bundy

(“Bundy”) both as a risk of non-appearance and as a danger to the safety of others

and the community.

Bundy is lawless and violent. He does not recognize federal courts – claiming

they are illegitimate – does not recognize federal law, refuses to obey federal court

orders, has already used force and violence against federal law enforcement officers

while they were enforcing federal court orders, nearly causing catastrophic loss of

life or injury to others. He has pledged to do so again in the future to keep federal

law enforcement officers from enforcing the law against him. As of the date of this

hearing, he continues to violate federal court orders and continues to possess the

proceeds of his illegal activities.

Bundy is currently charged with crimes of violence including using and

brandishing firearms in connection with crimes of violence under Title 18, United

States Code, Section 924(c). As such, the Bail Reform Act presumes that there are

no conditions or combination of conditions that will ensure the safety of the

community. 18 U.S.C . § 3142(e)(3)(B). Here, no evidence has been adduced during

the investigation of the instant charges that even remotely hints at a rebuttal to