The Court should remedy current prejudice and act to deter future Brady related misconduct, to
enforce the constitutional and rule based standards of fairness, and to impose appropriate sanctions for
the government’s cavalier approach to the discovery dispute up until now.
Respectfully submitted this 14th day of November 2017.
By: /s/ J. Morgan Philpot
J. MORGAN PHILPOT, ESQ.
Admitted Pro Hac Vice
JM Philpot Law, PLLC
Attorney for Defendant Ammon E. Bundy