Case 2:16-cr-00046-GMN-NJK Document 3598 Filed 04/22/24 Page 1 of 9

April 21, 2024

Honorable Judge Gloria Navarro

United States District Court
District of Nevada (Las Vegas)
333 Las Vegas Blvd South
Las Vegas, NV 89101. Via Email: [email protected]

In Re: Case 2:16-cr-00046-GMN

Dear Judge Navarro,

Please accept the attached declaration I am ling concerning the U.S.

Government’s Response In Opposition To Petition For Writ of Error Coram
Nobis (See: Docket #3594 Filed 04/17/24 - Case 2:16-cr-00046-GMN-
NJK).

After reviewing Steven Myhre’s response on behalf of the U.S.

Government, I believe it is now especially important to immediately and
formally declare some of the important facts and details pertaining to my
case, particularly the timeline which I was made aware of newly discovered
information which was not presented to me by my attorney at the time of
execution of my plea agreement.

I am also requesting appointment of a CJA attorney to assist me with

navigating through this process. Shortly after the execution of my plea
agreement, I was made aware that allegedly, a “Sealed Wooten
whistleblower document was received in our case, and that all of the
attorneys were brought in, advised of the document, and all attorneys were
threatened with jail time if the contents of the document were revealed to
even their clients/defendants.” Attorney Chris Rasmussen was my
Counsel of Record at the time of my plea agreement, and as a result of
recent conversations with Mr. Rasmussen, I believe he will become a
material witness in my case going forward.

Additionally, I am concerned about Assistant United States Attorney Steven

W. Myhre’s representation on behalf of the U.S. Government, as I have
recently reviewed many court lings, declarations and whistleblower
af davits which clearly implicate Mr. Myhre’s potential involvement in
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covering up the U.S. Government’s egregious misconduct. Although I

believe that if the allegations against Mr. Myhre are true, he should held
criminally and/or civilly liable for his prosecutorial misconduct, at the very
least, Mr. Myhre cannot overcome several glaring con icts of interest in any
pending or future matters relating to the Bundy cases.

In the interest of justice and truth, I am respectfully requesting that Mr.

Myhre’s representations contained in the Government’s Response
(Document 3594) on behalf of the U.S. Government be stricken from the
court docket in its entirety, and Mr. Myhre should begin the process of
having himself recused from the case, and any other Bundy cases until all
litigation has been satisfactorily resolved. If Mr. Myhre chooses not
voluntarily notify the EOUSA’s General Counsel’s Of ce (GCO), especially
considering that there is a very clear “appearance of a loss of impartiality”, I
intend to le a formal written notice to the U.S. Department Of Justice
asking that they enforce their own policies and procedures pertaining to
recusal as set forth in Title 3: EOUSA 3-1.140 as follows:

When United States Attorneys, or their of ces, become aware of an issue

that could require a recusal in a criminal or civil matter or case as a result
of an actual or apparent con ict of interest, they must contact EOUSA’s
General Counsel’s Of ce (GCO). United States Attorneys cannot recuse
themselves or their of ces from cases or matters. They must be recused
by the designated Associate Deputy Attorney General. The requirement of
recusal does not arise in every instance, but only where a con ict of
interest exists or there is an appearance of a loss of impartiality.

A United States Attorney who becomes aware of circumstances that might

necessitate his or her recusal or that of the entire of ce should promptly
notify GCO to discuss whether a recusal is required. If recusal is
appropriate, GCO will coordinate the recusal action, obtain necessary
approvals for the recusal, and arrange for a transfer of responsibility to
another of ce.

Judge Navarro, I want to also take this opportunity to inform you that the
alleged multi-faceted U.S. Government “operation to provoke and armed
confrontation with the American people” continues to this day, at least as it
relates to harassment of Defendants such as myself by known U.S
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Government agents and contractors. I currently possess credible

information, evidence, and will bring forth witness testimony to corroborate
various elements of my ongoing investigation which will shock the
conscience. Due to the extremely sensitive nature of this information,
some of which has been suppressed under “State Secrets Privilege”, and I
believe unlawfully because, as I am informed, a State Secrets Privilege
classi cation cannot be applied towards evidence of crimes against the
United States of America. I have con rmed, and will present credible
evidence, as well as transcribed court testimony by U.S. Government
Attorneys that this evidence is in safe keeping with the Central Intelligence
Agency’s Of ce of Inspector General.

At the time I entered my plea, and on the of cial court record, my Attorney
Chris Rasmussen presented to the Court that there were “rumors”
circulating in the public, and among my co-defendants, that I was an “FBI
Informant”. Mr, Rasmussen asked the court for the U.S. Government to
con rm whether or not I was ever an FBI informant. Steven Myhre
con rmed in open court that I have never had any contact, relationship, or
had been paid by the FBI. Although I was able to overcome the very
serious threats to my life during federal detention because of the public
rumors on the internet, the false information continues to this day. I
currently possess overwhelming documentation that I am continuously
harassed with false allegations of being an FBI informant, and audio
recordings from known government contractors who have been operating
at the behest of known agents for the Central Intelligence Agency. Due to
the information and evidence I currently possess, and intend to present as
evidence in my case regarding crimes against the United States of
America, the dangers and threats to my safety, security, and my life is very
grave and imminent, therefore, I am asking the court to immediately
demand that the U.S. Government issue a public declaration con rming
that I have never been an FBI Informant. In fact, there has already been
overwhelming evidence presented in court by U.S. Attorneys that the FBI
had assigned over “1000 online covert investigators” who are alleged to
have been involved in assisting with social media in uence operations
intended to fuel/in ame false rumors regarding my contacts with the FBI.
In addition to the threats posed to my life, this reputational harm has been
intended to destroy me nancially, and therefore decelerate my
investigations related to my case. I am con dent that these unlawful
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operations will be fully exposed through litigation, but the rst step is to
immediately address the ongoing, active methods which currently present
grave and potentially imminent danger to my life.

Judge Navarro, please know that throughout my entire federal detention

while incarcerated in Pahrump, I spoke with many defendants not
associated with our Bundy cases, and I always heard from Defendants who
were before you that you were an extremely fair judge. I never once heard
from a single defendant that you were anything but compassionate and fair.
As you have already determined at the time our case was dismissed, there
are people within our U.S. Government who have abused their power and
authority, perpetrated prosecutorial misconduct, and even Federal Agents
have blown the whistle regarding alleged improper, egregious, and
allegedly unlawful conduct in my case. The investigations and litigation
regarding these allegations continues to this day.

I respectfully ask for your thoughtful consideration of my requests, as well

as the compassion and fairness which, despite all circumstances related to
my case, I have always known, but never had an opportunity to disclose to
you. Please join me in the spirit of our continued efforts of bringing justice
in this very serious matter.

Respectfully Submitted,

Peter T. Santilli

See: Attached Declaration

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DECLARATION OF PETER T. SANTILLI

1. On or around the time of my sentencing, I was made aware by

a member(s) of the Joint Defense Counsel Team in the Bundy
cases that allegedly, a “Sealed Wooten whistleblower
document was received in our case, and that all of the
attorneys were brought in, advised of the document, and all
attorneys were threatened with ‘jail time’ if the contents of the
document were revealed to even their clients/defendants.” I
was not told about the contents of the Wooten memos, nor
was I made aware of its contents until approximately several
months ago.
2. I was informed, and therefore believed, that this new
information may have affected my decision to enter into a plea
agreement with the U.S. Government. Under the advisement
of Counsel, I began to review all of the relevant documents,
and was advised to “wait and see how the government
responds to the motion to compel production of the
documents showing they had legal authority, and what the
judge says” in response to the Government’s failure to
produce documents proving they had the lawful authority to
impound the cattle in April 2014. Although the government
has refused to publicly acknowledge they had no legal
authority to impound the cattle, they were compelled to do so
through litigation in a recent Tort Claim by my co-defendants.
The Tort claim by my co-defendants proceeded to discovery
by order of Federal Judge Hon William Q. Hayes presiding
over the case. At that time in November 2023, I was aware
that the government did not have the legal authority to
impound the cattle in 2014, and I intend to le a PETITION
FOR WRIT OF ERROR CORAM NOBISI with the assistance
of counsel.
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3. I have read all of the documentation submitted by Federal

Agent Larry Wooten in his rst and second ling. Upon
review of these allegations, it was very clear to me that if I
was aware of this information, I would never have entered my
plea, and I believe that if the allegations are true, that I could
never have impeded a convoy that should never have taken
place, nor was it a lawful government impoundment operation.
I also provided OCR copies of the Wooten Memo #1 and #2,
as well as the order signed by Hon William Q. Hayes (Case
2:22-cv-01040-WQH-EJY Document 42 Filed 11/20/23) to Eric
Parker.
4. The false, egregious, and intentionally harmful rumors which
have been circulating regarding me being an “FBI informant”
have not only posed a signi cant danger to my life and safety,
intentionally in icted reputational harm by self-described U.S.
Government contractor who has admittedly operated in
various capacities at the behest of a known Government CIA
operative in the intelligence community. The intentionally
false information has also directly impacted my ability to
obtain timely and effective counsel in exploring my legal
options related to my case. Through my example and recent
circumstances, the allegations of potential covert, criminal and
unlawful misconduct is continuing to this day, and I have
indisputable evidence which corroborates these allegations.
As has already been con rmed by the U.S. Government in
testimony at my plea hearing, I am not an FBI informant, I
have never been an FBI informant, I have never been paid by
the FBI, nor have I ever spoken to an FBI agent other than to
assert my 5th Amendment right to remain silent. This was the
rst and only time I have ever spoken to the FBI (outside of
my public reporting) which occurred during my booking in
2016 at Multnoma County jail in Portland Oregon.
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5. The allegations made by Larry Wooten in his 2 declarations

were not made available to me until approximately a few
months ago, at which time I immediately sought legal counsel.
I immediately recognized that if the allegations by Federal
Agent Larry Wooten are true, I do not believe I would have
been indicted, arrested and held for 619 days in pre-trial
detention.
6. The government, through Assistant U.S. Attorney Steven
Myhre, asserts in its response that the Wooten memos are
nothing more than bald conclusions about agent misconduct
conduct. This is not factual. The “BLM documents release”
led by Larry Klayman alleges multiple agencies lied to the
court, mentions multiple missing 302s from the FBI, and
missing or destroyed radio transmissions for the Tac channels.
Steven Myhre was admonished by the Court at trial in 2018
for prosecutorial misconduct, and withholding Brady material
which also contained exculpatory information about the
presence of “snipers”, which the indictment and Mr. Myhre
himself in open court falsely accused me and Cliven Bundy of
broadcasting false information with about snipers “for the
purpose of recruiting gunmen.”
7. Throughout my pre-trial detention, I was responsible for
organizing all of the discovery, and built a searchable
database for development by the Defendants and the Joint
Defense Team. Every document, photo, video and audio
recording was instantly accessible via the database I setup
organized, assembled and distributed to my co-defendants for
use in their trials. Since my release and sentencing in
October 2017, with the exception of the trial in 2018 when I
was informed that the prosecution asked that I “not assist
legal counsel of my fellow defendants with discovery”, I have
continued to assist my Tier 2 and tier 3 co-defendants and
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their attorneys with discovery questions relating to litigation in

their cases. Through the course of the litigation, I discovered
that exculpatory information emerged which had a direct
impact on my case as it related to my plea agreement. In the
Government’s Response (Document 3594 Filed 04/17/24)
Steven Myhre states that one of my co-defendants employed
a “bury one’s head in the sand until tapped on the shoulder”
approach. Since my false arrest in January 2016 initiated by
a fraudulent FBI 302 report claiming a witness stated I
conspired to take over the Malheur National Wildlife Refuge
(which resulted in my dismissal when the government
discovered the witness was going to testify that he never said
what the FBI 302 reported), I have worked tirelessly to help
expose prosecutorial and gross government misconduct. As a
result, over the past several years since my arrest, many
federal agents have been quietly walked out the door,
surrendered their badges and guns, and some have been
reportedly forced to retire or covertly reassigned to other
agencies. I am not aware of any co-defendant who has
buried their heads in the sand, and I hereby declare that I will
continue to work diligently until every U.S. Government
employee who deprived me and my co-defendants of their
Constitutional Rights Under Color of Law (18 U.S.C. §242) get
the “tap on the shoulder” in the form of accountability for their
alleged willful misconduct. Based on the information derived,
and has been recently been made known to me within the
past several months through litigation in the Tier 2 and Tier 3
defendants’ tort claims, I believe that Mr. Steven Myhre is now
potentially a Defendant in future claims I intend to bring forth,
and therefore I believe he should not be involved in any of my
future legal lings or responses. Mr. Myhre has been
previously admonished by the Court for prosecutorial
misconduct, and a whistleblower Federal Agent has submitted
credible evidence of Mr. Myhre’s alleged misconduct, and
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therefore, if the allegations are true, has allegedly had

involvement in my unlawful incarceration for 619 days.
8. Contrary to the maliciously false narrative crafted by
individuals within the U.S. Government, I have tremendous
respect for the Federal Judiciary. When I was initially
informed and discovered the contents of the Wooten Memo’s,
I waited until the Federal Judge Hon William Q. Hayes in the
case determined, after compelling them to produce the
requested documents, that the U.S. Government did not have
the legal authority to impound the cattle. Essentially, I was
informed that they allegedly lied to the court, lied to the Grand
Jury, lied in my indictment, and ultimately lied in my plea
agreement. The order proceeding with discovery was signed
in November 2023 by the Federal Judge acknowledging,
among many other things, that the U.S. Government ran an
operation for the purpose of provoking an armed confrontation
with the American People. That was the moment I
discovered very clearly that I was wrongfully indicted,
arrested, incarcerated and deceived into executing a plea
agreement.
I declare under penalty of perjury under the laws of The United
States of America that the foregoing is true and correct.

Peter T. Santilli