UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA v. MARIIA BUTINA, also known as, MARIA BUTINA, Defendant. : : : : : : : CRIMINAL NO. 18-CR-218 (TSC) UNDER SEAL MOTION FOR LEAVE TO FILE UNDER SEAL
The United States of America, by and through its attorney, the United States Attorney for the District of Columbia, respectfully moves this Court for leave to file under seal its Motion for Authorization of Transportation in the above-referenced case. The motion discusses a pending criminal investigation and matters occurring between the parties that should not appear in the public record. Although the fact of defendant Butina’s cooperation is now public, the details of her transportation to-and-from the jail are not. The disclosure of such information would pose a risk to the defendant’s safety and the safety of the community. Once disclosed, such information could be used by individuals or entities who might seek to harm or intimidate the defendant to prevent her from continuing to cooperate with law enforcement. As such, disclosure of this motion or any related papers may jeopardize defendant’s safety and may jeopardize the ongoing investigation. In addition, the proposed order references defendant Butina’s possible transportation to a grand jury. The fact of her testimony before a grand jury is protected under Rule 6(e) of the Federal Rules of Criminal Procedure and should remain confidential.
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2 Accordingly, the government hereby requests leave of the Court to file the above-referenced motion and any related documents under seal. Respectfully submitted, JESSIE K. LIU United States Attorney D.C. Bar No. 472845 By: /s/ THOMAS N. SAUNDERS Assistant United States Attorney N.Y. Bar No. 4876975 United States Attorney’s Office 555 Fourth Street, N.W. Washington, D.C. 20530 Telephone: 202-252-7790 Email: Thomas.Saunders@usdoj.gov
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