Case 3:16-cr-00051-BR

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IN THE UNITED STATES DISTRICT COURT FOR THE

DISTRICT OF OREGON
PORTLAND DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
SHAWNA COX,
Defendant.

Case No. 3:16-cr-00051-BR-7

PETITION/MOTION TO CHALLENGE
SUBSTANCE AND VALIDITY OF
COMPLAINT OF KATHERINE
ARMSTRONG
Dkt. #1)
(FRCrP Rule 3 1,3, 4, 5, 6, 7, 8 & 9 )

In accordance with Federal Rule of Criminal Procedures (FRCrP) Rule 3 Defendant

Shawna Cox, and respectfully challenges the substance of the complaint, the motive and
creditability of complainant Katherine Armstrong.
RESERVING MY RIGHT TO AMEND THIS MOTION
1. I, Defendant Shawna Cox respectfully requested the Grand Jury transcripts as
authorized in FRCrP from the prosecutors involved and the prosecutors involved
aggressively refused to allow me access to the Grand jury transcripts, because I
presume the transcripts will show no proper investigation was conducted by the
Grand Jury.

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2. It is not my fault the court is frustrated the council that was appointed to me did not
file these motions timely, but I will not waive my lawful protections identified in
Federal Rule of Criminal Procedures.
3. From the moment that the court allowed me to go Pro Se I had 90 days to file any
motions that were not filed on my behalf. The court is in error in attempting to make
me do it any faster.
4. With these two issues facing the court I reserve the right to amend my challenge to
Katherine Armstrongs complaint, after I receive the documentation I requested from
the Grand Jury proceedings.
CHALLENGES TO SUBSTANCE, MOTIVE AND CREDITABILITY OF
COMPLAINANT KATHERINE ARMSTRONG
I. Mandatory Nature of Rule: Requirements of these rules relating to a valid prearrest
complaint and the circumstances under which a warrant or summons shall issue must be
strictly complied with Brown v. Duggan D.C. Pa 1971, 329 F. Supp. 207.
5.

In accordance with FRCrP Rule 3, there is no Affidavit of Katherine Armstrong as

her Affidavit is not in the form of a proper affidavit. Form of complaint sec. 7001.

6. Katherine Armstrong, an agent of the King is prohibited from bringing a complaint.

See page 1 Introduction and Agent Background Magna Carta.
7. Katherine Armstrongs complaint is false, misleading and complete hearsay whereas:
a. On page 1 at 2 Ms. Armstrong states This affidavit is submitted to support a
criminal complaint, yet there is no criminal complaint filed by anyone except
Ms. Armstrong who was not (as indicated in the complaint itself) the damaged
party. This raises the essential civil question that needs to be answered before
any court can proceed, which is Who is the damaged party(s)? A government
employee? The ranchers trying to earn a living so they can pay taxes so the

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government can employ individuals? The people of Oregon? The witnesses

and informants? Since no individual damaged party has come forward just
who is the damaged party?
b. As indicated on page 2 at 3 Ms. Armstrongs knowledge is limited to the
events that she identified elsewhere in her dictations such as her knowledge
the Bundys were protesting the re- sentencing of the Hammonds and
challenging the land titles to the lands of the Malheur (MNWR) that are
clouded.
c. Ms. Armstrong acknowledges the Bundy defendants have taken Adverse
Possession of the MNWR and are challenging the land titles to the property
but in malice she intentionally omits the fact the proper way to address
adverse possessors is a civil ejection action with the alleged lawful landowner
bringing a civil quiet title action and trespass action.
d. In malice Ms. Armstrong intentionally omits documenting the fact there was
multiple opportunities for law enforcement to peacefully serve the Bundy
defendants with a civil quiet title ejection action, but the alleged lawful
landowner refused to follow proper civil lawful procedures.
e. In malice Ms. Armstrong intentionally omits documenting the fact Alleged
lawful landowner held a malicious and vengeful attitude and was determined
to aggressively resist litigating their lawful ownership of the MNWR.
f. In an attempt to be judge, jury, plaintiff, defendant, plaintiffs counsel
defendants counsel and witnesses Ms. Armstrong states the MNWR is federal
property, of which until it is properly litigated is a presumption that may
eventually be proven fraudulent.
8. I consider these extremely serious acts of omission by Ms. Armstrong and others
criminal with malice and vengeance involved whereas; she admits and documents
herself she has conspired with others to circumvent civil law and harass, threaten and

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intimidate me (and others) a victim, witness and informant of government overreach

and judicial branch corruption.
9. Katherine Armstrongs complaint is also vague and ambiguous whereas:
a. There is no proper affidavit or complaint filed by a damaged party, as she
implies on page 1 in paragraph 2 there is.
b. She claims to have witnesses but omits any and all statements of her
witnesses.
c. On page 4 & 5 at 11 Ms. Armstrong implies Sheriff David Ward had the
power and a lawful right to circumvent lawful procedures and force the
Bundys from their adverse possession of the MNWR without the landowner
bringing forth a lawful quiet title action, which is false and misleading.
d. On page 4 at 8 Ms. Armstrong implies the Hammonds voluntarily distanced
themselves from the Bundys and omits the fact that they were under threat of
longer sentences if they did not.
e. When stating the facts related to the Hammonds resentencing Ms. Armstrong
omits the fact that hundreds of thousands of innocent individuals are
improperly prosecuted, defended, tried, convicted and incarcerated by a less
than adequate judicial industry. I intent to call Att. Kathleen T. Zellner &
Ryan Ferguson as Expert witnesses.
f. Ms. Armstrong omits very important facts that led to the persecution of the
Hammonds including the fact that large Corporate Ranches with the ability to
corruptly solicit politicians through donations to their campaigns, have desires
to acquire the grazing rights the Hammonds held.
g. Ms Armstrong fails to point out that insider trading and purchasing pecuniary
benefits is illegal and never properly investigated or argued in the prosecution
of the Hammonds. See page 5 at 12.

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h. On page 6 at 14 Ms. Armstrong omits including or referring to a criminal

complaint witness CB filed with the Harney County Sheriffs office that
identified the individuals who harassed the Citizen were FBI and law
enforcement officers, that where attempting to incite a riot and / or hostility
against the Bundy defendants in order to justify their use of force and
weapons against the Bundy defendants.
i. Ms. Armstrong omits pointing out the fact that there is a nationwide
movement for gun control and political supporters of the gun control
movement were motivated to take advantage of the situation and incite
hostility and violence in order to push their agenda.
j. Ms. Armstrong omits pointing out the fact that it is this type of government
tactics and strategies that led to the need of the Militia to defend themselves
against out of control government operatives.
k. Ms. Armstrong omits pointing out the fact that the Bundys were desperately
trying to achieve a civil resolution instead of a violent resolution.
l. On page 7 & 8 at 17 Ms. Armstrong admits that there was no one home or
at work when the Bundy defendants took adverse possession of the MNWR.
m. Paragraphs 18 & 19 are intended (as most of Ms. Armstrongs fiction is) to
obtain an emotive response from the readers.
n. Specifically Ms. Armstrongs fictional writing defeats count two of having a
firearm in a government facility whereas in paragraph 19 she implies with
some form of certainty; In 2014, there were 23, 967 visitors to the MNWR
including birders, hunters and outdoor recreationists. In this statement she
acknowledges it is an acceptable practiced to be armed with firearms in and
on the MNWR.
o. Paragraph 20 is vague overly broad and ambiguous as it fails to identify any
single individual that was threatened by any other single individual.

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Somewhere a person needs to state clearly that another person they can
identify threatened them. Mere conclusory allegations are insufficient. U.S.
Beasley, C.A. Okl. 1973 458 F. 2d 60
p. Like the pattern of falsities that occur throughout Katherine Armstrongs
complaint paragraph 21 on page 9 & 10 is vague and ambiguous as it lacks
any personal knowledge of an unidentified senior official who appears not
to have been present. Giordenello v. U.S., Tex. 1958, 78 S.Ct. 1245, 357 US
480, 2 L.Ed. 577.
q. Paragraph 22 on page 10 is overly broad, vague, ambiguous and a clear stretch
of government overreach.
r. It appears in paragraph 23 the unidentified Harney County Sheriffs Officer
and his source are the individuals witness CB caught harassing Citizen in an
attempt to create hostility, violence and a riot, and without the individuals
identified submitting statements it lacks personal knowledge.
s. Clearly the substance included in paragraph 24 is insufficient in every aspect,
as it identifies no one, no one present with personal knowledge, who made an
assumption not supported by facts. There were no signs posted anywhere on
the Refuge stating weapons were not allowed. There are in fact a number of
hunts annually on the Refuge in which hundreds of hunters are carrying
weapons. The Refuge itself has a number of weapons of their own.
t. I, defendant Shawna Cox, do not disagree with the statements Ms. Armstrong
made on page 22 about me personally, and I stipulate she does not identify
any crime I committed or participated in, neither does she relate me with a
criminal activity other than a simple trespass that shouldve been brought
forth timely in a civil quiet title ejectment action.

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Dated this 17th day of August, 2016.

By ___________________________
Shawna Cox pro se All Rights and Protections Reserved