Free State Reporting, Inc. Court Reporting/Transcription D.C. Area 301-261-1902 Balt.& Annap. 410-974-0947

Case 2:12-cv-00804-LDG-GWF Document 19-5 Filed 12/21/12 Page 1 of 20
UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEVADA
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:
UNITED STATES OF AMERICA,
:
:
Plaintiff,
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v.
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CLIVEN D. BUNDY,
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Defendant
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Case No.
2:12-CV-804-LDG-GWF
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333 Las Vegas Boulevard, South

Las Vegas, Nevada
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Tuesday, October 23, 2011

Deposition of:
CLIVEN D. BUNDY
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a witness, called for examination by counsel for the
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Plaintiff, pursuant to notice and agreement as to time and
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place, at the United States Attorneys Office, Las Vegas,
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Nevada, before Sandy A. Dahlheimer, a Notary Public, where
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were present on behalf of the respective parties:
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FREE STATE REPORTING, INC.
Court Reporting/Transcription
D.C. Area 301-261-1902
Balt.& Annap. 410-974-0947
U.S. Mot. Summ. J. - Ex. 4

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A P P E A R A N C E S
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On Behalf of the Plaintiff:
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TERRY M. PETRIE, ESQ.

United States Department of Justice
Environment and Natural Resources Division
Natural Resources Section
999 18th Street, South Terrace
Suite 370
Denver, Colorado 80202
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NANCY C. ZAHEDI, ESQ.

GREGORY LIND, ESQ.
Department of the Interior
Office of the Solicitor
Pacific Southwest Region
2800 Cottage Way
Suite E-1712
Sacramento, California 95825
ALICE C. NEWTON
Lake Mead National Recreation Area
601 Nevada Way
Boulder City, Nevada 89005
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LAUREN BROWN
Bureau of Land Management
4701 North Torrey Pines Drive
Las Vegas, Nevada 89130
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On Behalf of the Defendant:
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CLIVEN D. BUNDY, IN PRO PER

Post Office Box 7175
Bunkerville, Nevada 89007
702-346-5564
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Also Present:
Carol Bundy
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D.C. Area 301-261-1902
Balt.& Annap. 410-974-0947

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Do you see that, sir?
A.
Yes, I understand it.
Q.
Sir, you've seen this document before?
A.
Yes, I have.
Q.
Thank you.
Sir, that's just simply to establish
we're having a deposition today and here's the document
that lined it up.
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Sir, have you ever been deposed before in a

proceeding like this?
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A.
One other time.
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Q.
When was that?
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A.
It's been several years dealing with a Department
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Yes, I have.
of Transportation, State of Nevada.
14
Q.
Anything to do with cattle?
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A.
Yeah, it was.
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Q.
Can you tell us what that was about?
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A.
We had cattle get hit on the freeway, and I was
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in there giving deposition on that case.

Q.
Was this a case brought by the Department of
Transportation?
A.
No.
I was with them.
They sued -- or State of
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Nevada, I guess, and it was my cattle involved so they sued
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me also, and there was a contractor involved.
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them so there's a three-way suit with a private, you know,
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party suing.
D.C. Area 301-261-1902
Balt.& Annap. 410-974-0947
They sued

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Q.
I understand.
So the "they" that you're
mentioning are the people whose car hit the cattle?
A.
Yes.
Q.
Was this like in a local State Court or District
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Court?
A.
State Court.
It was a case, which in the freeway
fence, you know, we have the open range laws, but this was
inside the freeway fence so they had a case against the
State because of, you know, maintenance or our gate wasn't
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closed -- that type of thing.

Q.
About where was this accident?
About where did
it happen?
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A.
Probably about mile marker 115, I-15 North.
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Q.
Okay.
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A.
Yeah. I don't know.
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This was several years ago?

At least over ten years ago
probably.
17
Q.
Any other depositions, sir?
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A.
That's the only one.
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Q.
I've been deposed myself so it's quite an
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experience.
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Sir, let me go through a couple of basics about
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this deposition.
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talk to you about your cattle operations as a general
24
subject.
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First, in a big general way, I want to
When I ask you questions, if you don't understand

D.C. Area 301-261-1902
Balt.& Annap. 410-974-0947

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A.
No.
Q.
Since the year 2000 -- my question is going to
focus from the year 2000 through today -- have you grazed
your cattle on lands both inside the former Bunkerville
Allotment, which you now have characterized here today as
your ranch, as well as lands outside of the Bunkerville
Allotment outside your ranch?
A.
Yes.
Q.
Has that been done routinely over the course of
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those now 12 years?
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A.
Yes.
12
Q.
When you graze your cattle, is there some kind of
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a system or methodology that you use with it?
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words, is it like a continuous grazing operation that you
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have out there?
In other
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A.
Yes.
17
Q.
Year round basically?
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A.
Yes.
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Q.
What I'm going to do here, sir -- let's go off
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the record.
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(Off the record.)
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(On the record.)
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BY MR. PETRIE:
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Q.
What I'm going to do, sir, is hand you a map that
we'll mark as Exhibit 4 that was prepared for this case.

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questions up to this point, if I might express, you know,
you asked me if I run cattle on the Bunkerville -- old
Bunkerville Allotment, and you asked if I run cattle on the
new trespass land, and my answer is yes; then you hand me a
map that is a lot broader in my thinking that I had cattle
so there's a problem there.
question before I seen the map.
record.
Q.
In other words, I answered the

Make that part of the
That's a good point, and I appreciate that.
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have an appreciation for that, and indeed where I'd like to
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go next -- and I apologize because I can tell as an aside
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from your manner, your demeanor, that you feel a little
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perturbed like maybe I mislead you.
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because that certainly was not my intent.
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And I apologize
What I'd like to do next is what I'd like you to
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do is to mark on this map certain things.
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include your understanding of where you ran your cattle,
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that sort of thing.
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here is not meant to suggest -- and let's just use this as
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an example of my point -- if you take a look at the map,
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sir, that we have marked, sir, as Exhibit 4.
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Okay?
Okay.
To
So that, for example, the map
You see -- if you take a look at where I-15 as it
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works its way northeast from Las Vegas how it eventually
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intersects into the portion of the map where you see the
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new trespass lands being denoted with the hash marks and
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A.
It's all right.
Q.
What we might do is if I could ask somebody to go
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I think I'll be able to --
to the main office -A.
I've got it good enough.
We'll scratch it on
there.
Q.
We really want it -- if you could indulge me here
for a moment, sir, and we'll go off the record.
hopefully a better marker device and ask you to just
retrace it so it's clear to anybody that looks at it
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they'll be able to figure out what you drew there.

A.
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Yes, I'll do that.

MR. PETRIE:
We can go ahead and go off the
record.
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(Off the record.)
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(On the record.)
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BY MR. PETRIE:
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We'll have
Q.
Mr. Bundy, we're back on the record.
And during
the break, we took steps to address a failing on my part.
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Lawyer 101 says you have markers that make
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bright, delible marks that are easy for all to see; and the
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original instrument we used, a red ink pen, was not up to
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the task.
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So what we've done is over that red ink line and
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we have asked you and you have retraced that red line with
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a black Magic Marker; is that correct, sir?

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A.
Yes.
Q.
And, again, just for the record here so that it's
clear, those black lines represent by your understanding
the outer limits of where your cattle have grazed?
A.
Yes.
Q.
I'm going to hand you, sir, another document.
We'll have this marked as Exhibit 7.
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(Whereupon, Exhibit 7 was marked for

identification.)
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BY MR. PETRIE:
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Q.
I think this will look familiar to you.
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A.
Well, I got interested in reading, I guess.
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Q.
Sir, do you recognize this document?
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A.
Well, let me go through it a little bit more.
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Q.
Sure.
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A.
Okay.
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Q.
Sir, I'm focused specifically on the first page.
I recognize at least part of it.
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Sir, does this document appear to be information contained
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on a blog spot that's titled bundyranch.blogspot.com?
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A.
Yes.
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Q.
Sir, on the first page of this exhibit, there's
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an entry that's dated May 12, 2012.
Do you see that?
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A.
Yes.
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Q.
And at the bottom of that entry appears to be
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your name, Cliven D. Bundy.

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A.
Right.
Q.
Where is the Gold Butte headquarters located?
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And let's go ahead and mark it again on this map.
use the black marker and we'll just use HQ to denote that.
A.
This thing turned round right here. HQ?
Q.
Yes, sir.
A.
(Witness complies.)
Q.
Thank you.
We'll
And this appears to be located in
what would be the southeast corner of the area that you
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previously marked for the outer limits for where you
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understand your cattle have grazed; is that correct, sir?
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A.
Yes.
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Q.
And that appears to be a portion of the map,
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which the Government contends is new trespass lands?
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A.
Yes.
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Q.
Thank you.
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Speaking of the cattle that were grazing, sir, we
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talked earlier about how your ranch has employed the use of
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brand marks and earmarks, brands and earmarks; is that
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right, sir?
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A.
Yes.
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Q.
Okay.
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Some of the cattle that you have grazed,
are they unbranded?
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A.
Yes.
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Q.
About what percentage, if you've got a sense of

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that?
A.
On the knoll -- new trespass land, I would just
estimate -- you wanted to know about the branded or
nonbranded now?
Q.
Nonbranded.
A.
I would say approximately 40 percent of them are
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nonbranded.
Q.
If -- don't laugh at this question because it's
probably got a very logical answer, but you're fielding a
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question from a guy who does not run cattle.
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like Petrie, he goes out there and he comes across one of
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your unbranded cattle.
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that would tell Petrie that, yes, this cow belongs to
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Cliven Bundy?
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A.
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For somebody
Is there anything about the cow
Two things, the genetic of the animal and the
herd it was running with.

Q.
The latter suggesting that, if an unbranded cow
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is in the presence of other Bundy marked cattle, there is
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pretty good odds it's also a Bundy cow?
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A.
Yes.
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Q.
I wasn't clear on that and I appreciate you're
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educating me.
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Sir, and this will revisit an item we were
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discussing earlier, but specifically to the new trespass
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lands, do you have any kind of fee title to any of those

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Nevada statute's saying that State of Nevada has as it says
in NRS 321.596 that the State of Nevada has a strong moral
claim to the land?
A.
A strong moral claim?
Q.
Yeah.
If you actually read the first statute in
that citation, but aside from the strong moral claim
language, I understand that you're saying the effect of
that statute allows you to use, but it's not the same thing
as a lease; is it?
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A.
No, it's not.
But it is a form of a lease, I
guess, if I have the rights.
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Q.
Form of an authorization to use it?
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A.
Yes.
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Q.
But it's just not the typical lease?
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A.
No, it's not a typical lease between you and me.
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Q.
Okay.
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I get what you're saying there and I
appreciate that.
Sir, do you -- and, again, it's the same line of
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questions here -- do you have any authorization from BLM to
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use any of the new trespass lands that the Government, BLM,
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administers on behalf of the United States recognizing that
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you dispute the ownership of it but nonetheless BLM does
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carry out activities to administer some of the lands
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located within the new trespass?
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authorization from them?
Do you have any kind of

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A.
No.
Q.
How about -- the same question but from the
vantage point of Nation Park Services.
kind of authorization from National Park Service?
A.
No.
Q.
Okay.
(Off the record.)
(On the record.)
BY MR. PETRIE:
Q.
Do you have any
Let's just take a quick break.
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Sir, are you aware that the Federal Government
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has designated certain portions of the lands out there in
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the Gold Butte area as lands where it has designated
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habitat for different species to be protected under the
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Endangered Species Act such as the desert tortoise and the
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southwestern willow fly catcher?
Are you aware of that?
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A.
Yes.
17
Q.
Sir, do you have any understanding about whether
18
or not your cattle in the course of their grazing have
19
sometimes damaged the vegetation and the habitat for these
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different species?
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A.
No.
22
Q.
Are you aware that your cattle have sometimes
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eaten newly planted vegetation in areas, which are trying
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to restore the land, the vegetation on it?
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A.
No.
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A.
Could be.
Q.
Okay.
A.
Could be.
Q.
30?
A.
Could be.
Q.
How about 50?
A.
Could be.
Q.
Okay.
A.
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on that land.
12
Q.
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How about 20?
At what point would you say definitely no,
I don't have 100, or I don't have 200?
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Any sense of that?
Well, I probably have near 100 range improvements
So that we're clear, when you say "that land," is
that the former Bunkerville?
14
A.
Yes, the Bundy ranch.
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Q.
Okay.
How about same line of questions?
I'm
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just trying to get a sense of the number for range
17
improvements in what the government characterizes as new
18
trespass lands.
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A.
I have none.
20
Q.
None?
21
A.
Let me clarify some things that have happened
Okay.
22
there that I've had something to do with.
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there's a waterline broke or a water not getting into the
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water trough, if I go there, I fix that waterline and put
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it in the trough if I can do it.
For example, if
There's been a couple of

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occasions where I've done that kind of improvement or
maintenance, either way you want to call it; and I do that
for two purposes.
I do it for more than two purposes.
One, I do it because it does benefit any
livestock or wildlife that's in the area.
thing for a human to come along there with a broken car or
something and needs a drink, and it's a waste of a resource
if I can do some kind of improvement.
two or build a dam or put a pipeline together all the time,
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12
It's a safety
I'll move a rock or
even if it's on new trespass land.

Q.
I understand.
Then the waterlines that you're
referring to, are sometimes those waterlines in pipes?
13
A.
Yes.
14
Q.
And you've repaired pipes that were burst or
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16
broken or cracked out there in the new trespass land?

A.
Maybe one or two in the sense of fixing it,
17
putting it into the trough and making sure the water is not
18
wasted. No type of major maintenance on a waterline have I
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ever done in the new trespass lands.
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21
Q.
Do you have any understanding as to who placed
the water trough or the water pipeline?
22
A.
Only that the prior ranch owners did that.
23
Q.
Do you have any understanding about whether or
24
not the pipeline or water troughs that you have come across
25
in the new trespass lands were placed there initially for

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livestock purposes or for any other purpose?
any sense of that?
Do you have
A.
It was for livestock and wildlife.
Q.
I'm not doubting you when I ask this.
What's the
basis for your understanding that it was placed there
initially for those purposes?
A.
The benefit of wildlife and cattle.
Q.
I'm asking how it is that you know that?
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Is it
because the person who placed it there told it to you, for
10
example, or is it just common sense that tells you that out
11
here in the middle of nowhere it's got to be for that
12
reason?
13
A.
No.
Your question is partly yes.
That's part of
14
the reason, but the other part is that I've witnessed
15
livestock and wildlife using those things, and I know that
16
they've been improved by man, which I assume the rancher is
17
the man that improved that.
18
talks about the Gold Butte area now, not Gold Butte area
19
but Gold Butte.
20
The new trespass land mainly
We're talking about one hundred plus years of
21
range improvements on that that are still existing.
22
They're still there, and so the pipelines, the head houses,
23
the troughs, the trails -- all those things still exist
24
upon that land even though there's not a rancher there.
25
Q.
Okay.
Do you have any authorization from BLM or

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from NPS for any range improvements since the year 2000 out
in the former Bunkerville Allotment?
A.
No.
Q.
How about same question since the year 2000, but
in this instance for the new trespass lands?
A.
No.
Q.
If you need to, please do.
A.
Just on temporary use of say trails, say
I could back up a little bit.
temporary trails, the Park Service has okayed that type of
10
action, and I really don't have anything in writing, but
11
they've provided me with a lock and key to get into their
12
property and to do those kind of things.
13
up a temporary trail and fences and then basically took
14
them down when they're through.
15
done some of that kind of work on that land.
16
And we have put
So in other words, I have
Q.
Have you placed salt licks on the new trespass
18
A.
Yes.
19
Q.
How about placing hay on the new trespass land?
20
A.
Only for trapping.
21
Q.
Trapping --
22
A.
Trapping cattle.
17
23
24
25
land?
In other words, try to gather
those cattle off that land.

Q.
Have you -- I think you answered this earlier so
I apologize if I'm being redundant.
In the new trespass

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help orient you, I'm going to show you a map that's a USGS
map, and it says BLM 2005 Nevada, Lake Mead, and the scale
is 1 to 100,000.
And what I'm going to do is show you a place on
this map that's marked as Mockingbird Spring.
that, sir?
You see
A.
Okay.
Q.
And then in conjunction with where that's
located, if you can then take a look at Exhibit 4 and get
10
an idea roughly from comparing the two maps where
11
Mockingbird Spring would be --
12
A.
This is what we call headquarters right here.
13
Q.
Yes, sir.
14
A.
And Mockingbird Spring -- I don't know where it
15
16
17
is so show me.
Q.
It's to the west of what
you called headquarters, Mockingbird Spring.
18
19
It's right here, sir.
Do you see the entry here on the USGS map?

A.
Okay.
I can see it.
I never know that was
20
Mockingbird Spring, but now Quail is a little more
21
familiar.
22
Q.
Quail Spring, yes.
23
A.
Okay.
24
Q.
Well, the question I had was whether or not you
25
Ask me what you want to know.
have used a corral at the Mockingbird Spring site?

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3
A.
Definitely, no.
If somebody's used a corral,
then it must be somebody stealing my cows.

Q.
Do you know if -- and I phrased the question in
the context of you using a corral.
a corral there even if you haven't used it?
91
A.
Do you know if there's
No, I don't believe -- in my way of looking at
this map, there's no corral there.
Quail, Spring Quail Wash.
Spring.
Let me see.
Well,
I know where that is.
Quail
10
You know, I don't know -- if that's Mockingbird
11
in the way I'm looking at this, I might have to take that
12
statement back.
13
yes, I have trapped some cattle or attempted to trap cattle
14
there.
15
know where that is, and I know there's a good corral there.
16
So I would assume that that's probably a corral that I have
17
used. I mean, I think I probably used it one time and in
18
the last say several years to try to trap some cattle
19
there.
20
21
Q.
I don't know what the name of it was, but
And if I'm looking at this at Quail Spring Wash, I
And so there, as you think further, that perhaps
indeed there is a corral there that was used?
22
A.
Yeah, I think so.
23
Q.
Any idea who put that corral there in the first
24
25
Yes.
place?
A.
Well, it's prior ranchers.
I don't know whether

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Now, let's go back to the question.
Let's assume
the federal authorities have the authorization to present
themselves on land, whether you call it your ranch or the
former Bunkerville Allotment, or for that matter the new
trespass lands, and they've got the authorization in hand
to remove cattle that belongs to you and they literally,
physically, take the steps necessary to accomplish that
right there and you're standing by.
9
10
99
Are you going to undertake any effort to

physically stop that?
11
A.
Yes.
12
Q.
What efforts would that be?
13
A.
Whatever it takes.
14
Q.
Okay.
Would that include -- when you say
15
"whatever it takes," would that include the soliciting, the
16
assistance of neighbors, friends, family, supporters of
17
yours to do whatever it takes in the scenario I just
18
described?
19
A.
Yes.
20
Q.
Whatever it takes -- well, no.
Okay.
21
Sir, as you know, there was an earlier
22
proceeding, an earlier case, that the United States brought
23
against you back in the late '90s, 1998, 1999.
24
25
Do you recall that the Court issued an order for

you to remove your cattle that the Court determined were
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trespassing on the lands that we call the former
2
Bunkerville Allotment and which you now call the Bundy
ranch?
Do you recall that?
A.
Yes.
Q.
You never removed your cattle, did you?
A.
Right.
Q.
Sir, one last question here and we'll let you and
your wife get on with your day.
it takes, this is going to be a tame ending.
10
After that topic, whatever
If you would take a look at the answer that you
11
filed in this case -- and I don't think I have it marked as
12
an exhibit, and I'll do that right now and we'll mark it as
13
Exhibit 12.
14
15
It's the answer that you filed in this case.
(Whereupon, Exhibit 12 was marked for

identification.)
16
BY MR. PETRIE:
17
Q.
Sir, does that document look familiar to you?
18
A.
Yes, I'm familiar with it.
19
Q.
It's the answer that you filed in this Court in
20
response to the Government's complaint, and your answer was
21
filed on June 4, 2012.
22
Sir, on page 3, if you would, if you'd take a
23
look at that on page 3, and this touches on something that
24
at least tangentially we addressed earlier, but there's
25
another phrase in here I wanted to ask you about.

D.C. Area 301-261-1902
Balt.& Annap. 410-974-0947

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Case 2:12-cv-00804-LDG-GWF Document 19-5 Filed 12/21/12 Page 1 of 20

UNITED STATES DISTRICT COURT

333 Las Vegas Boulevard, South

Tuesday, October 23, 2011

a witness, called for examination by counsel for the

Plaintiff, pursuant to notice and agreement as to time and

place, at the United States Attorneys Office, Las Vegas,

Nevada, before Sandy A. Dahlheimer, a Notary Public, where

were present on behalf of the respective parties:

U.S. Mot. Summ. J. - Ex. 4

Case 2:12-cv-00804-LDG-GWF Document 19-5 Filed 12/21/12 Page 2 of 20

TERRY M. PETRIE, ESQ.

NANCY C. ZAHEDI, ESQ.

On Behalf of the Defendant:

CLIVEN D. BUNDY, IN PRO PER

U.S. Mot. Summ. J. - Ex. 4

Case 2:12-cv-00804-LDG-GWF Document 19-5 Filed 12/21/12 Page 3 of 20

Do you see that, sir?

Yes, I understand it.

Sir, you've seen this document before?

Sir, that's just simply to establish

we're having a deposition today and here's the document

that lined it up.

Sir, have you ever been deposed before in a

One other time.

When was that?

It's been several years dealing with a Department

of Transportation, State of Nevada.

Anything to do with cattle?

Can you tell us what that was about?

We had cattle get hit on the freeway, and I was

in there giving deposition on that case.

Was this a case brought by the Department of

I was with them.

They sued -- or State of

Nevada, I guess, and it was my cattle involved so they sued

me also, and there was a contractor involved.

them so there's a three-way suit with a private, you know,

U.S. Mot. Summ. J. - Ex. 4

Case 2:12-cv-00804-LDG-GWF Document 19-5 Filed 12/21/12 Page 4 of 20

So the "they" that you're

mentioning are the people whose car hit the cattle?

Was this like in a local State Court or District

It was a case, which in the freeway

inside the freeway fence so they had a case against the

State because of, you know, maintenance or our gate wasn't

closed -- that type of thing.

About where was this accident?

About where did

Probably about mile marker 115, I-15 North.

Yeah. I don't know.

This was several years ago?

Any other depositions, sir?

That's the only one.

I've been deposed myself so it's quite an

Sir, let me go through a couple of basics about

talk to you about your cattle operations as a general

First, in a big general way, I want to

When I ask you questions, if you don't understand