Government’s Motion to Seal Complaint — No. 2:21-mj-01027 (Dkt. 2, D. Nev.)

Summary

Assistant U.S. Attorney Jim W. Fang moved on December 10, 2021, in Case No. 2:21-mj-01027 in the District of Nevada, to seal the complaint against Luigi J. Montes, Alexander Hoyos Rivera and Peter Alexander Stincer. The motion says the complaint refers to an ongoing investigation and that none of the defendants was yet in custody, so disclosure could lead them to flee, resist arrest or destroy evidence. A proposed order for Magistrate Judge Daniel J. Albregts would seal the complaint, the motion and the sealing order until further order.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Record facts

Full text

Case 2:21-mj-01027-DJA   Document 2   Filed 12/10/21   Page 1 of 4

             Case 2:21-mj-01027-DJA          Document 2        Filed 12/10/21     Page 2 of 4




 1   CHRISTOPHER CHIOU
     Acting United States Attorney                              FILED.
 2   Nevada Bar Number 14853                                    DATED: 2:46 pm, December 10, 2021
     JIM W. FANG
 3   Assistant United States Attorney                           U.S. MAGISTRATE JUDGE
     501 Las Vegas Boulevard South, Suite 1100
 4   Las Vegas, Nevada 89101
     Phone: (702) 388-6336
 5   Email: jim.fang@usdoj.gov
     Attorneys for the United States of America
 6
                                  UNITED STATES DISTRICT COURT
 7                                     DISTRICT OF NEVADA

 8    UNITED STATES OF AMERICA,

 9                   Plaintiff,

10           v.                                        Case No. 2:21-mj-
11    LUIGI J. MONTES,                                 GOVERNMENT’S MOTION
                                                       TO SEAL COMPLAINT
12    ALEXANDER HOYOS RIVERA, and
                                                       (Filed Under Seal)
13    PETER ALEXANDER STINCER,

14                          Defendants.

15

16          The United States of America, by and through Christopher Chiou, Acting United

17   States Attorney, and Jim W. Fang, Assistant United States Attorney, respectfully moves this

18   Honorable Court for an Order sealing the Complaint, together with this Motion and the

19   Court’s Sealing Order, in the above-captioned matter until such time as the Court, or

20   another Court of competent jurisdiction, shall order otherwise.

21          It is necessary for the Complaint in this case to be sealed in light of the fact that it

22   makes reference to information regarding an on-going investigation. Public disclosure of the

23   information in the Complaint might possibly jeopardize the investigation because all three

24   defendants are not yet in custody. If they were to find out that federal law enforcement

             Case 2:21-mj-01027-DJA          Document 2       Filed 12/10/21     Page 3 of 4




 1   officers were attempting to effectuate their arrests, defendants may attempt to flee, hide, or

 2   otherwise make their arrests more difficult or impossible. They may also make preparations

 3   to actively resist arrest, potentially placing law enforcement officers in danger, as well as

 4   destroy evidence they may have in their possession related to their criminal conduct.

 5          To facilitate defendants’ arrests, the Government respectfully requests that this Court

 6   grant the Government’s motion and seal the Complaint in this case, as well as this Motion

 7   and the Court’s Order on this Motion.

 8          DATED this 10th day of December, 2021.

 9                                                       Respectfully submitted,
                                                         CHRISTOPHER CHIOU
10                                                       Acting United States Attorney

11

12                                                       JIM W. FANG
                                                         Assistant United States Attorney
13

14

15

16

17

18

19

20

21

22

23

24


                                                     2

             Case 2:21-mj-01027-DJA        Document 2        Filed 12/10/21   Page 4 of 4




 1                     UNITED STATES DISTRICT COURT
 2                          DISTRICT OF NEVADA
                                                                FILED.
 3    UNITED STATES OF AMERICA,
                                                                DATED: 2:46 pm, December 10, 2021
 4                   Plaintiff,                                 U.S. MAGISTRATE JUDGE
 5           v.

 6    LUIGI J. MONTES,
                                                       Case No. 2:21-mj-
 7    ALEXANDER HOYOS RIVERA, and

 8    PETER ALEXANDER STINCER,

 9                          Defendants.

10

11                   Order Granting Government’s Motion to Seal Complaint

12                                        (Filed Under Seal)

13          Based on the pending Motion of the Government, and good cause appearing, IT IS

14   HEREBY ORDERED that the Complaint, the Motion, and this Court’s Sealing Order in

15   the above-captioned matter shall be sealed until further Order of the Court.

16          DATED this ______ day of December, 2021.

17

18
                                            HONORABLE DANIEL J. ALBREGTS
19                                         UNITED STATES MAGISTRATE JUDGE

20

21

22

23

24


                                                   3

File and source

File

2.pdf

Size

569,477 bytes

SHA-256

13689ba7a104b8c33c6d86117bd54856b9151833b20e69f89236e0d160f4aeb1

Our copy

2.pdf