Assented to Motion for Leave to File Sentencing Memorandum Under Seal as to Chynna Savath — USA v. Savath (Dkt. 16, D. Mass.)

Summary

Defendant Chynna Savath's assented-to motion for leave to file her sentencing memorandum under seal in United States of America v. Chynna Savath, Criminal No. 1:21-cr-10269-RGS, in the U.S. District Court for the District of Massachusetts, filed May 27, 2022 as Document 16. The motion states that on January 20, 2022, under a plea agreement under Fed. R. Crim. P. 11(c)(1)(C), Savath pled guilty to a two count information charging her with wire fraud in violation of 18 U.S.C.§ 1343, and that sentencing is scheduled for June 2, 2022 at 2:00 p.m. It says the memorandum will address sentencing factors under 18 U.S.C. § 3553(a), including private and personal information already disclosed to the Probation Office and the government. The United States has assented. It is signed by Daniel J. Cloherty of Todd & Weld LLP.

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UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF MASSACHUSETTS 
 
__________________________________________ 
 
 
 
 
 
 
 
) 
UNITED STATES OF AMERICA,  
 
) 
 
 
 
 
 
 
 
) 
 
v. 
 
 
 
 
 
)   Criminal No.:  1:21-CR-10269 
 
 
 
 
 
 
 
) 
CHYNNA SAVATH,  
 
 
 
) 
 
 
 
Defendant. 
 
 
) 
__________________________________________) 
 
ASSENTED-TO MOTION FOR LEAVE TO FILE 
SENTENCING MEMORANDUM UNDER SEAL 
 
 
Defendant Chynna Savath, by and through her undersigned counsel, hereby moves this 
Court for an Order authorizing her to file her Sentencing Memorandum in this case under seal.  
As grounds for this Motion, undersigned counsel states as follows: 
1. On January 20, 2022, pursuant to a plea agreement under Fed. R. Crim. P. 
11(c)(1)(C), Defendant Savath pled guilty to a two count information charging her 
with committing wire fraud in violation of 18 U.S.C.§ 1343.  Sentencing in this case 
is scheduled for Thursday, June 2, 2022 at 2:00 p.m. 
2. Defendant Savath intends to submit a short Sentencing Memorandum addressing the 
circumstances of the case, as well as certain of the sentencing factors under 18 U.S.C. 
§ 3553(a), including her own personal history and characteristics.  The Sentencing 
Memorandum will address, in part, private and personal information relating to her 
health care. 
3. The private and personal information to be addressed in her Sentencing Memorandum 
has been previously disclosed to the Probation Office and government counsel, but 
Defendant requests that the information not be placed in the public record. 
Case 1:21-cr-10269-RGS     Document 16     Filed 05/27/22     Page 1 of 2

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4. Undersigned counsel has conferred with government counsel regarding the subject 
matter of this Motion, and the United States has assented to the relief requested 
herein. 
WHEREFORE, Defendant Savath respectfully requests that this Court issue an Order 
authorizing her counsel to file her Sentencing Memorandum in this matter under seal. 
 
 
 
 
 
 
 
Respectfully submitted, 
DEFENDANT, CHYNNA SAVATH, 
By her attorney, 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/s/ Daniel J. Cloherty  
 
 
 
 
 
 
 
 
Daniel J. Cloherty (BBO# 565772) 
 
 
 
 
 
 
Todd & Weld LLP 
 
 
 
 
 
 
One Federal Street 
 
 
 
 
 
 
Boston, MA  02110 
 
 
 
 
 
 
(617) 720-2626 
 
 
 
 
 
 
 
dcloherty@toddweld.com  
 
 
CERTIFICATE OF SERVICE 
 
I, the undersigned, hereby certify that I served a true copy of the above document upon 
all parties with an interest in this matter by electronically filing through this Court’s CM/ECF 
filing system this 27th day of May, 2022. 
 
 
 
 
 
 
/s/ Daniel J. Cloherty 
 
 
 
 
 
 
 
 
 
 
Daniel J. Cloherty 
 
  
Case 1:21-cr-10269-RGS     Document 16     Filed 05/27/22     Page 2 of 2

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