SEALED EX PARTE APPLICATION to Seal Case Filed by Plaintiff USA as… — USA v. Western Distribution, LLC. et al (Dkt. 3)

Summary

Government's Ex Parte Application for Order Sealing Documents with a Declaration of Matthew W. O'Brien, Document 3, filed 07/01/21 in No. CR 21- (UNDER SEAL), Case 5:21-cr-00170-JGB, Central District of California, four pages. The caption names defendant Carl Bradley Johansson with several aliases, and the related complaint number 5:21-mj-00461 is stamped on it. Assistant U.S. Attorneys Joseph O. Johns and Matthew W. O'Brien ask that the complaint, the application and related papers stay under seal until the defendant is taken into custody. O'Brien declares that Johansson has not been arrested or told he will be named, and that disclosure first could hinder agents in locating him and give him time to dispose of or conceal evidence. It is dated July 1, 2021 and signed /s/ by O'Brien under Acting U.S. Attorney Tracy L. Wilkison.

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TRACY L. WILKISON 
Acting United States Attorney 
SCOTT M. GARRINGER 
Assistant United States Attorney 
Chief, Criminal Division 
JOSEPH O. JOHNS (Cal. Bar. No. 144524) 
MATTHEW W. O’BRIEN (Cal. Bar No. 261568) 
Assistant United States Attorneys 
Environmental and Community Safety Crimes Section 
1300 United States Courthouse 
312 North Spring Street 
Los Angeles, California 90012 
Telephone: (213) 894-4536/8644 
Facsimile: (213) 894-0141 
E-mail: 
joseph.johns@usdoj.gov 
Matthew.O’Brien@usdoj.gov
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
UNITED STATES DISTRICT COURT 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
CARL BRADLEY JOHANSSON, 
  aka “Brad Johansson,”  
  aka “Brad Johnson,”  
  aka “Carl Johnson,” 
  aka “C. Brad Johanson,” 
  aka “Jay Johnson,” 
  aka “Keith Golatta,”
Defendant. 
 No. CR 21- 
(UNDER SEAL)  
07/01/2021
jbb
5:21-mj-00461
jbb
FILED
CLERK, U.S. DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
BY: ___________________ DEPUTY
07/01/2021
Case 5:21-cr-00170-JGB     Document 3     Filed 07/01/21     Page 1 of 4   Page ID #:51

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TRACY L. WILKISON 
Acting United States Attorney 
SCOTT M. GARRINGER 
Assistant United States Attorney 
Chief, Criminal Division 
JOSEPH O. JOHNS (Cal. Bar. No. 144524) 
MATTHEW W. O’BRIEN (Cal. Bar No. 261568) 
Assistant United States Attorneys 
Environmental and Community Safety Crimes Section 
1300 United States Courthouse 
312 North Spring Street 
Los Angeles, California 90012 
Telephone: (213) 894-4536/8644 
Facsimile: (213) 894-0141 
E-mail: 
joseph.johns@usdoj.gov 
Matthew.O’Brien@usdoj.gov
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
UNITED STATES DISTRICT COURT 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
CARL BRADLEY JOHANSSON, 
  aka “Brad Johansson,”  
  aka “Brad Johnson,”  
  aka “Carl Johnson,” 
  aka “C. Brad Johanson,” 
  aka “Jay Johnson,” 
  aka “Keith Golatta,”    
 Defendant. 
No. CR 21- 
GOVERNMENT’S EX PARTE APPLICATION 
FOR ORDER SEALING DOCUMENTS; 
DECLARATION OF MATTHEW W. O’BRIEN 
(UNDER SEAL)  
Plaintiff United States of America, by and through its counsel 
of record, the United States Attorney for the Central District of 
California and Assistant United States Attorneys Joseph O. Johns and 
Matthew W. O’Brien, hereby applies ex parte for an order that the 
government’s complaint, as well as this ex parte application and any 
related documents in the above-titled case be kept under seal until 
the defendant is taken into custody on the charges contained in the 
5:21-mj-00461
Case 5:21-cr-00170-JGB     Document 3     Filed 07/01/21     Page 2 of 4   Page ID #:52

 
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complaint. 
This ex parte application is based upon the attached declaration 
of Matthew W. O’Brien. 
Dated: July 1, 2021 
Respectfully submitted, 
 
TRACY L. WILKISON 
Acting United States Attorney 
 
SCOTT M. GARRINGER 
Assistant United States Attorney 
Chief, Criminal Division 
 
 
 /s/      
 
MATTHEW W. O’BRIEN 
JOSEPH O. JOHNS 
Assistant United States Attorneys 
 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
 
 
Case 5:21-cr-00170-JGB     Document 3     Filed 07/01/21     Page 3 of 4   Page ID #:53

 
 
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DECLARATION OF MATTHEW W. O’BRIEN 
I, Matthew W. O’Brien, declare as follows: 
1. 
I am an Assistant United States Attorney in the United 
States Attorney’s Office for the Central District of California.  I 
am one of the attorneys representing the government in this case.  
2. 
The government requests leave to file its complaint and any 
related documents (except the arrest warrant) as well as this ex 
parte application in the above-titled case under seal. 
3. 
Defendant CARL BRADLEY JOHANSSON (“JOHANSSON”) has not yet 
been taken into custody and has not been informed that he will be 
named as a defendant in this case.  If the complaint in this case or 
any related documents were made public before JOHANSSON is taken into 
custody, the ability of law enforcement to locate and apprehend him 
could be jeopardized.  Furthermore, public disclosure of the 
affidavit in support of the complaint in this case before JOHANSSON 
is apprehended would allow JOHANSSON time to dispose of or conceal 
evidence. 
I declare under penalty of perjury under the laws of the United 
States of America that the foregoing is true and correct and that 
this declaration is executed at Los Angeles, California, on July 1, 
2021. 
 
/s/ 
 
MATTHEW W. O’BRIEN 
Case 5:21-cr-00170-JGB     Document 3     Filed 07/01/21     Page 4 of 4   Page ID #:54

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