Case 3:16-cr-00051-BR Document 1178 Filed 09/02/16 Page 1 of 7 J. Morgan Philpot (Oregon Bar No. 144811) Marcus R. Mumford (admitted pro hac vice) 405 South Main, Suite 975 Salt Lake City, UT 84111 (801) 428-2000
[email protected] [email protected] Attorneys for Defendant Ammon Bundy IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON UNITED STATES OF AMERICA, Case No. 3:16-cr-00051-BR Plaintiff, REPLY IN FURTHER SUPPORT OF THE v. MOTION TO DISMISS FOR LACK OF AMMON BUNDY, et al, SUBJECT MATTER JURISDICTION RE: ADVERSE POSSESSION Defendants. The Honorable Anna J. Brown Apparently taking its cue from the Court’s dismissive docket order [#1161], the government files a one-paragraph response to Mr. Bundy’s motion challenging the Court’s subject matter jurisdiction, which brings to mind the memorable exchange from the classic film The Treasure of the Sierra Madre (Warner Bros. 1948) between a bandit (Alfonso Bedoya) and Fred Dobbs (Humphrey Bogart): BANDIT: We are federales. You know, the mounted police. DOBBS: If you are the police, where are your badges? BANDIT: Badges? We ain’t got no badges. We don’t need no badges. I don’t have to show you any stinking badges!1 The government’s response says, essentially, we don’t need to prove no stinking subject matter jurisdiction! But that’s the thing: they do. And Mr. Bundy’s motion raises serious issues, based on the 1 See https://www.youtube.com/watch?v=VqomZQMZQCQ (last visited 9/2/16); credit Dickerson v.