Sealed- Motion to Seal by USA as to Ahmed M Sary — USA v. Sary (Dkt. 3, D. Md. No. 1:22-mj-01286)

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This copy of the government's motion to seal, Document 3 docketed under Case 1:23-cr-00344-RDB in the U.S. District Court for the District of Maryland and filed April 29, 2022, covers magistrate case numbers 1:22-mj-01286-JMC through 1:22-mj-01290-JMC and asks that the criminal complaint, arrest warrant, search warrants and affidavit concerning Ahmed M. Sary be placed under seal until further order of this Court. It states that disclosure could jeopardize an ongoing investigation of alleged wire fraud (18 U.S.C. § 1343), wire fraud conspiracy (18 U.S.C. § 1349) and money laundering (18 U.S.C. § 1956).

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Case 1:23-cr-00344-RDB     Document 3     Filed 04/29/22     Page 1 of 2
“LOGGED ____ RECEIVED

10:20 am, Apr 29 2022

AT BALTIMORE
CLERK, U.S. DISTRICT COURT

IN THE UNITED STATES DISTRICT COURT DISTRICT OF MARYLAND
FOR THE DISTRICT OF MARYLAND BY Deputy
1:22-mj-01286-JMC
IN THE MATTER OF THE SEARCH 1:22-mj-01287-JMC
OF: , 1:22-mj-01288-JMC
| 1:22-mj-01289-JMC
THE PERSON AND PREMISES 1:22-mj-01290-JMC
DESCRIBED IN ATTACHMENTS A-1 Case No. 1-23 =mi= O94 ME
THROUGH A-5; AND , ,

Filed Under Seal
THE CRIMINAL COMPLAINT AND

ARREST WARRANT OF AHMED M.
SARY

GOVERNMENT’S MOTION TO SEAL

The United States of America respectfully moves this Court for an order sealing the _
affidavit submitted in support of the above-referenced Criminal Complaint, arrest warrant, search
warrants, and related documents, and in support thereof states:

1. The affidavit submitted in support of the above-refenced Criminal Complaint,
arrest warrant, and search warrants contains information regarding an ongoing investigation
related to alleged violations of Wire Fraud (18 U.S.C. § 1343), Wire Fraud Conspiracy (18 U.S.C.
§ 1349), and Money Laundering (18 U.S.C. § 1956).

2. | Disclosure of the Criminal Complaint, arrest warrant, affidavit, and related
documents at this time could seriously jeopardize the investigation as it would reveal the name and
identity of the target of the investigation who is unaware of the scope of the ongoing federal
investigation and who, if he—or any confederates—becomes aware, may attempt to destroy
evidence, or otherwise obstruct justice. Therefore, disclosure of the affidavit at this time would
in all likelihood compromise the integrity of the investigation and could quite possibly jeopardize
the outcome of the investigation.

3. To. seal an affidavit, the government must demonstrate that: (1) there is a
Case 1:23-cr-00344-RDB     Document 3     Filed 04/29/22     Page 2 of 2
compelling government interest requiring materials to be kept under seal and (2) there is no less
restrictive means, such as redaction, available. Jn re Search Warrants Issued on April 26, 2004,
353 F. Supp. 2d 584 (D. Md. 2004). The procedures for sealing are set.forth in Baltimore Sun
Co, v. Goetz, 886 F.2d 60 (4th Cir. 1989). “The judicial officer may explicitly adopt the facts
that the government presents to justify the sealing.” Jd. at 65. This motion and the Court’s reasons
for sealing should also be sealed. Jd. Notice of the sealing is required, but the notice
requirement is satisfied by the docketing of the order sealing the documents, Jd.
WHEREFORE, the government respectfully requests that above-referenced Criminal
Complaint, arrest warrant, search warrants and supporting affidavit, along with this motion and
the Court’s reasons for sealing, if made express in the order, be placed under seal until further

order of this Court.

Respectfully submitted,

Erek Barron
United States Attoyney

Paul A. Riley

Assistant United States Attorney

36 South Charles Street, Fourth Floor
Baltimore, Maryland 21201


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