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Government's Motion to Seal - Page 1
IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION
___________________________________________
UNITED STATES OF AMERICA ' FILED UNDER SEAL ' No. 3:13-CR-030-L v. ' ' BARRETT LANCASTER BROWN '
GOVERNMENTS MOTION TO SEAL THE GOVERNMENTS OPPOSITION TO
BROWNS MOTION TO DISMISS THE INDICTMENT [Doc. 56]
1. The United States Attorney for the Northern District of Texas, by and through the
undersigned Assistant United States Attorney, files this Motion to Seal its Motion in
Opposition to Browns Motion to Dismiss the Indictment. In an abundance of caution, the
government requests that its Motion in Opposition be filed under seal, due to the terms of
the Agreed Protective Order (Doc. 36) and to the Courts September 4, 2013 Agreed Order
Re: Extrajudicial Statements (53).
2. Although the defense chose to file its motion publically, the government does not
think it appropriate to publish a response that sets out evidentiary items not yet made
public.
3. Attached hereto is the governments proposed Motion in Opposition to Browns
Motion to Dismiss the Indictment.
Case 3:13-cr-00030-L Document 59 Filed 03/19/14 Page 1 of 2 PageID 250
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Government's Motion to Seal - Page 2
4. The government respectfully requests that this Honorable Court seal the
Governments Opposition to Browns Motion to Dismiss, this Motion to Seal, and the
Courts Order Sealing.
Respectfully submitted,
SARAH R. SALDAA UNITED STATES ATTORNEY
S/ Candina S. Heath
CANDINA S. HEATH Assistant United States Attorney State of Texas Bar No. 09347450 1100 Commerce Street, 3rd Floor Dallas, Texas 75242 Tel: 214.659.8600 Fax: 214.767.2846 [email protected]
CERTIFICATE OF CONFERENCE I hereby certify that on March 19, 2014, I consulted with Ahmed Ghappour
regarding this motion, and he did not object to filing the motion under seal.
S/ Candina S. Heath CANDINA S. HEATH Assistant United States Attorney
CERTIFICATE OF SERVICE I hereby certify that on March 19, 2014, I electronically filed the foregoing
document with the clerk for the U.S. District Court, Northern District of Texas, using the electronic case filing (ECF) system of the court. The ECF system sent a "Notice of Electronic Filing" to Browns attorneys of record Ahmed Ghappour, Charles Swift, and Marlo Cadeddu, who consented in writing to accept this Notice as service of this document by electronic means.
S/ Candina S. Heath CANDINA S. HEATH Assistant United States Attorney
Case 3:13-cr-00030-L Document 59 Filed 03/19/14 Page 2 of 2 PageID 251