Government’s Ex Parte Application for Order Sealing Indictment (No. 2:22-cr-00205, C.D. Cal.)

Summary

The government's ex parte application for an order sealing the indictment and related documents, with a declaration of Gregory Bernstein, was filed 05/12/22 as Document 57 in Case 2:22-cr-00205-JFW in the Central District of California, in the case against Natalie Le Demola et al. It asks that the indictment and related documents be sealed until the government files a "Report Commencing Criminal Action," under Federal Rule of Criminal Procedure 6(e)(4). In the declaration, Assistant United States Attorney Gregory Bernstein states that the defendants are not aware of the pending indictment and that publishing it could jeopardize the government's ability to safely apprehend them. The application and declaration are dated May 11, 2022.

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STRICT COU

Case 2:22-cr-00205-JFW Document 57 Filed 05/12/22 Page 1of2 Page |D,f:23@.EP

RT

05/12/2022

CENTRAL DISTRICT OF CALIF

TRACY L. WILKISON mn
United States Attorney BY: —__] 7 _Dep

DRNIA
UTY

SCOTT M. GARRINGER
Assistant United States Attorney
Chief, Criminal Division
GREGORY BERNSTEIN (Cal. Bar No. 299204)
Assistant United States Attorney
Major Frauds Section
1100 United States Courthouse
312 North Spring Street
Los Angeles, California
Telephone: 213-894-3183
Email: Gregory.Bernstein@usdoj.gov

Attorneys for Plaintiff
UNITED STATES OF AMERICA

UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, CR 2:22-cr-00205-JEW
Plaintiff, GOVERNMENT’S EX PARTE APPLICATION
FOR ORDER SEALING INDICTMENT AND
Vv. RELATED DOCUMENTS; DECLARATION OF

GREGORY BERNSTEIN

NATALIE LE DEMOLA ET AL.,
(UNDER SEAL)
Defendant.

The government applies ex parte for an order that the indictment
and related documents in the above-titled case be sealed until the
government files a “Report Commencing Criminal Action.” This ex parte
application is made pursuant to Federal Rule of Criminal Procedure
6(e) (4) and is based on the attached declaration of Gregory
Bernstein.

Dated: May 11, 2022 Respectfully submitted,

GREGORY BERNSTEIN
Assistant United States Attorney

Attorneys for Plaintiff
UNITED STATES OF AMERICA
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Case 2:22-cr-00205-JFW Document 57 Filed 05/12/22 Page 2of2 Page ID #:237

DECLARATION OF BERNSTEIN

I, Gregory Bernstein, 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
represent the government in the prosecution of the above-captioned
case.

2. The indictment in this case will imminently be presented to
a federal grand jury in the Central District of California.

3. The defendants in this case are not aware of the pending
indictment. Publishing the indictment on the open docket could
jeopardize the government’s ability to safely apprehend the
defendants.

4. Accordingly, the government requests that the indictment
and sealed documents in this case, except the arrest warrants, be
sealed until one of the defendants is taken into custody on the
charges contained in the indictment and the government files a
“Report Commencing Criminal Action.”

5. 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 in the Central District of

California on May 11, 2022.

GREGORY BERNSTEIN
ASSISTANT UNITED STATES ATTORNEY


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