Case 3:16-cr-00051-BR Document 2519 Filed 02/21/18 Page 1 of 14


This is The Sentencing Memorandum for the previously Shared 91 Page Exhibit A

B. Factual Background

The underlying facts of defendant’s case are accurately set forth in paragraphs 14 through

36 of the Presentence Report (hereafter “PSR”).

1. Pre-Occupation

Defendant Payne has a long history of opposing the authority of the federal government.

In 2013, Payne cofounded Operation Mutual Aid (OMA). The purpose of OMA was to create a

network of militiamen to respond to situations involving conflict with the government and law

enforcement. In 2014, OMA issued a formal call to action for militia forces to respond to

Bunkerville, Nevada, to support the Bundy family’s conflict with the Bureau of Land

Management (BLM). In April of 2014, Payne traveled to Nevada and was named “Militia

Coordinator” for the Bundy family. He recruited and organized armed militia groups to

respond to the confrontation with the BLM.

After BLM suspended the impoundment action, Payne and others cited the events in

Bunkerville, Nevada, as a significant victory for their movement and evidence that the federal

government lacked authority to manage federal lands.

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