Motion to Seal Criminal Complaint — United States v. Daniel Joseph Tisone (M.D. Fla., No. 2:22-mj-1043)

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A motion to seal the criminal complaint and related documents in United States of America v. Daniel Joseph Tisone, Case No. 2:22-mj-1043-DNF, in the U.S. District Court for the Middle District of Florida, filed March 30, 2022 as Document 1. The United States asks the Court to direct the Clerk to seal the complaint, the attached affidavit, the warrant copies and other documents that would identify the defendant, stating that disclosure before arrest could hinder arrest efforts. It also asks that the United States Marshals Service may release certified copies of the arrest warrant, and that the documents be unsealed when any named defendant is taken into custody. The three-page motion is signed for United States Attorney Roger B. Handberg by Trenton J. Reichling.

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Case 2:22-cr-00039-SPC-NPM Document 1 Filed 03/30/22 Page 1 of 3 PageID 1
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
FORT MYERS DIVISION
UNITED STATES OF AMERICA
v. CASE NO. 2:22-mj-1043-DNF
DANIEL JOSEPH TISONE
MOTION TO SEAL CRIMINAL COMPLAINT
AND RELATED DOCUMENTS
Pursuant to Fed. R. Crim. P. 6(e)(4), and in the interests of law
enforcement, the United States of America by Roger B. Handberg, United
States Attorney for the Middle District of Florida, hereby moves the Court to
direct the Clerk to seal the Criminal Complaint, the attached affidavit, the file
copy of the warrant(s), defendant information sheet(s), this motion, the
Court's order regarding this motion and any other documents filed in this case
that would identify the defendant(s). Disclosure of the existence of these
documents prior to the arrest of a defendant could hinder or impede arrest
efforts.
The United States further moves that the Court direct the Clerk to seal
the Criminal Complaint in this case except when necessary to provide certified
copies of the Criminal Complaint to the United States Attorney's Office.
The United States further requests that the Court's Order allow the
FILED
2022 MAR 30 AM 10:21
[illegible]
Case 2:22-cr-00039-SPC-NPM Document 1 Filed 03/30/22 Page 2 of 3 PageID 2
United States Marshals Service to release certified copies of the arrest warrant
to the case agent or other appropriate law enforcement and/or to the United
States Attorney's Office, upon verbal request of the United States Attorney's
Office to the United States Marshals Service, without further order of the
Court.
The United States further requests that the Court’s Order allow the
United States Marshals Service or other appropriate law enforcement agency
to enter the arrest warrant into the National Crime Information Center
(NCIC) database or other appropriate law enforcement database, without
further order of the Court.
The United States further requests that the Court's Order allow the
United States to disclose the existence of the Criminal Complaint in any
subsequent search and/or seizure warrants which may be executed in
conjunction with the arrest of the defendant(s).
The United States further moves that the Court direct the Clerk to
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Case 2:22-cr-00039-SPC-NPM Document 1 Filed 03/30/22 Page 3 of 3 PageID 3
unseal the documents described herein without further order when any named
defendant is taken into custody.
Respectfully submitted,
ROGER B. HANDBERG
United States Attorney
By: [illegible]
Trenton J. Reichling
Assistant United States Attorney
Florida Bar No. 0084601
2110 First Street, Suite 3-137
Ft. Myers, Florida 33901
Telephone: (239) 461-2200
Facsimile: (239) 461-2219
E-mail: Trenton.reichling@usdoj.gov

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