Motion to Seal by USA as to Alexander Barabash — USA v. Barabash (Dkt. 3, D. Md.)

Record facts

U.S. District Court for the District of Maryland · No. 1:22-cr-00232-JKB · Doc. 3 · 2022-06-29 · Docket on CourtListener

Full text

SEALED
IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF MARYLAND
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CRIMINAL NO.
UNITED STATES OF AMERICA
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USDC- BALTIHORE 
’22 JUN 23 pm3:20
UNDER SEAL
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v.
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ALEXANDER BARABASH
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Defendant
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MOTION TO SEAL
The United States of America, by its undersigned attorneys, files this motion requesting
that the Court order that the indictment and all related documents in this matter be sealed until
further order of the Court, and in support says as follows:
The Fourth Circuit has recognized that a motion to seal may be granted for any
1.
legitimate prosecutorial need, including the proper completion of any investigation. In re Knight
Publishing Co.. 743 F.2d 231,231-32 (4th Cir. 1984).
Law enforcement is conducting an on-going investigation.
2.
The defendant, Alexander Barabash, has not been arrested.
3.
Disclosure of the indictment and arrest warrants, at this juncture, would seriously
4.
jeopardize this on-going criminal investigation; may cause the destruction or tampering with of
evidence; and will notify targets of law enforcement's knowledge of their operations, and may
cause targets to flee to avoid prosecution.
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Case 1:22-cr-00232-JKB     Document 3     Filed 06/29/22     Page 1 of 2

WHEREFORE, the government respectfully moves to seal the above captioned indictment,
arrest warrants, all related documents, and this Motion and Order until further Order of the Court
to protect an on-going criminal investigation.
Respectfully submitted.
Erek L. Barron 
United States Attorney
Digitally signed by Darryl 
Louis Tarver 
Date: 2022.06.28 
09:58:26 -04,00'
4HJ-
By:
Darryl L. Tarver
Assistant United States Attorney
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Case 1:22-cr-00232-JKB     Document 3     Filed 06/29/22     Page 2 of 2

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