Case: 1:20-cr-00424-CAB Doc #: 30 Filed: 10/15/20 1 of 2.

PageID #: 171

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF OHIO
EASTERN DIVISION

UNITED STATES OF AMERICA, ) CASE NO.: 1:20CR424

)
Plaintiff, ) JUDGE CHRISTOPHER A. BOYKO
)
v. )
)
MARGARET COLE, et al., ) MOTION TO PARTIALLY UNSEAL
) SEARCH WARRANTS, APPLICATIONS
Defendants. ) AND AFFIDAVITS IN SUPPORT

Now comes the United States of America, by and through its undersigned counsel, and

respectfully moves the Court for an Order partially unsealing the search warrants, applications

and affidavits in support filed under Case Nos. 1:17MJ3036, 1:17MJ3037, 1:17MJ3038,

1:17MJ3039, 1:17MJ3040, 1:17MJ3083, 1:17MJ3084, 1:17MJ3085, 1:17MJ3086, 1:17MJ3087,

1:17MJ3088, 1:17MJ3089, 1:17MJ3090, 1:17MJ3091, 1:17MJ3092, 1:17MJ3093, 1:17MJ3094,

1:17MJ3095, 1:17MJ3096, 1:17MJ3097, 1:17MJ3098, 1:17MJ3099, 1:17MJ3100, 1:17MJ3101,

1:17MJ3102, 1:17MJ3103, 1:17MJ3104, 1:17MJ3105, 1:17MJ3106, 1:17MJ3107, 1:17MJ3108,

1:17MJ3109, 1:17MJ3110, 1:17MJ3111, 1:17MJ3112, 1:17MJ3113, 1:17MJ3114, 1:17MJ3115,

1:17MJ3116, 1:17MJ3117, 1:17MJ3126, and 1:17MJ3127, so that the government may disclose

them to defense counsel in connection with on-going discovery production in this case, pursuant

to Rule 16 of the Federal Rules of Criminal Procedure.

The search warrants, including the applications and affidavits in support, were ordered

sealed at the government’s request. Because the above-described sealed documents contain

specific information about cooperating individuals and other witnesses, contain specific

information regarding uncharged conduct, and contain information about individuals who have
 Case: 1:20-cr-00424-CAB Doc #: 30 Filed: 10/15/20 2 of 2. PageID #: 172

not been charged with criminal conduct, including minors, the government requests that it not be

required to fully unseal these documents. Instead, the government asks that it be permitted to

disclose copies of these sealed documents only to each defense counsel of record, who will be

permitted to share these documents with their respective clients pursuant to the Protective Order

in this case. The government requests that the orders currently in place sealing the above-

described documents remain intact with only a partial unsealing for the limited purpose of

providing discovery to defendants under the terms of the Court’s previously-issued protective

order.

Accordingly, the United States of America respectfully moves the Court to enter an Order

partially unsealing the search warrants, applications and affidavits in support filed in the above-

referenced case numbers. A proposed order is attached.

Respectfully submitted,

DANIEL KHAN JUSTIN E. HERDMAN

ACTING CHIEF U.S. ATTORNEY
FRAUD SECTION NORTHERN DISTRICT OF OHIO

s/ Jason M. Manning, s/Alex Kramer s/ Chelsea S. Rice

JASON M. MANNING
ALEX KRAMER
Trial Attorneys
Fraud Section
1400 New York Avenue NW
Washington, D.C. 20005
(202) 514-6256/307-0955
Jason.Manning@usdoj.gov /
Alexander.Kramer@usdoj.gov
CHELSEA S. RICE
Assistant United States Attorney
400 United States Court House
801 West Superior Avenue
Cleveland, Ohio 44113
(216) 622-3752
Chelsea.Rice@usdoj.gov