Case 3:16-cr-00051-BR

Document 1037

Filed 08/15/16

Page 1 of 2

Ryan Bundy, Pro Se

Inmate: Swis# 795070
Multnomah County Detention Center
11540 NE Inverness Drive
Portland, OR 97220
Telephone: (503) 988-3689
Defendant
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF OREGON
UNITED STATES OF AMERICA,

Case No. 3:16-cr-00051-BR-05

Plaintiff,
vs.
RYAN BUNDY,
Defendant.

DEFENDANTS EXPERT WITNESS

QUALIFICATIONS AND SUMMARY
OF ANTICIPATED TESTIMONY
Judge: Hon. Anna J. Brown

Pursuant to Rule 16(b)(1)(C) of the Federal Rules of Criminal Procedure, Pro Se

Defendant Ryan Bundy notifies the Court and counsel of his intent to call Charles P.
Stephenson as a defense expert on use of force.
I.

QUALIFICATIONS, TRAINING AND EXPERTISE

Charles Stephenson is a former FBI agent, FBI instructor, SWAT/Firearms
instructor, Defensive tactics instructor, and FBI National Academy instructor. As
an FBI agent, he is trained and experienced in law enforcement situations and
confrontations involving firearms, including experience with so-called armed
stand-offs, and knows first-hand the pressure on law enforcement agents trying to
execute their duties. Since leaving public service, Mr. Stephenson has been
certified as an expert in the field of force science where the factual issues
presented most frequently involve lawful vs. unlawful use of force in both state

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OF ANTICIPATED TESTIMONY

Case 3:16-cr-00051-BR

Document 1037

Filed 08/15/16

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and federal court proceedings. A copy of his resume is attached to this

declaration as Exhibit 1.
II.

SUMMARY OF ANTICIPATED TESTIMONY

It is anticipated that Mr. Stephenson will testify about the proper and accepted
protocols for handling firearms, and law enforcement experience and training in
responding to situations involving firearms, including the training that federal
agents and others receive regarding use of force and certain terms of art or
indicators used within the community of gun owners and law enforcement that
help distinguish peaceful actions from threatening actions. It is further anticipated
that Mr. Stephenson will testify regarding force science issues presented in this
case, such as open carry, alleged threats or intimidation regarding the use of force,
and what actions or facts indicate and distinguish brandishing from peaceful
actions involving firearms. Finally, it is anticipated that he will also address the
FBIs history of the use of force, hallmarks of a paramilitary operation, mistakes
the FBI has made in prior high-profile uses of force, and the impact those
mistakes have had on public trust.

Respectfully submitted this 15th day of August, 2016.

/s/ Ryan Bundy*
Pro Se Defendant

*Filed on behalf of Mr. Bundy by standby counsel Lisa J. Ludwig, OSB #953387

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