Government's Sealing Application (N.D.N.Y., Dkt. 4, April 2, 2021)

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Government's Sealing Application, Document 4, filed 04/02/21, in the U.S. District Court for the Northern District of New York, Case 3:22-cr-00082, dated April 2, 2021. The United States applies under NDNY Criminal Local Rule 13.1 for sealing of documents requesting an order authorizing investigative activity or an arrest warrant, the Court's order, the application and the sealing order. It states that public filing may jeopardize an ongoing federal criminal investigation, the safety of a person who provided assistance, and the safety of law enforcement personnel. It asks that the documents remain under seal until further order, with arrest-warrant documents unsealed upon the arrest, and is signed /s/ Andrew D. Beaty.

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Ty DISTRI COURT - NLD. OF N.Y.

‘Case:3;2 22- C0 GQ82- NH Document 4 Filed 04/02/21 Page 1 of 2 4)

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In Re...
CRIMINAL COMPLAINT

ITED STATES DISTRICT COURT
RTHERN DISTRICT OF NEW YORK

Government’s Sealing Application
Filed Under Seal
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The United States of America, by and through its counsel of record, the United States Attorney
for the Northern District of New York [“NDNY”], hereby applies to the Court pursuant to NDNY
Criminal Local Rule 13.1 for the sealing of the following: (a) one or more documents submitted to
the Court at the same time as this sealing application, which document(s) request a Court order
authorizing certain investigative activity or an arrest warrant; (b) the Court’s order authorizing such
investigative activity or an arrest warrant; (c) this sealing application; and (d) the Court’s sealing
order, which has the same caption.

The United States respectfully requests such sealing because public filing of the above-

described documents may:

nA Jeopardize an ongoing federal criminal investigation by revealing the existence of that
investigation to potential targets and subjects of the investigation;

Jeopardize the safety of a person who has provided information and/or other assistance to
the criminal investigation or the family and/or friends of such person by revealing such
person’s cooperation with the investigation to those under investigation or their associates;

Jeopardize the safety of law enforcement personnel;

Reveal law enforcement methods, techniques, and/or procedures, thereby jeopardizing
future investigations using such methods, techniques, and/or procedures;

Reveal non-public information about one or more victims and/or witnesses and such
information could lead to adverse financial and/or social consequences for such person(s);
Reveal non-public information about one or more targets or subjects of the investigation
who have not been charged with a crime in the relevant investigation and such information
could lead to adverse financial and/or social consequences for such person(s);

Reveal matters in violation of federal law, such as Rule 6(e) of the Federal Rules of
Criminal Procedure and/or Title 26, United States Code, Section 6103;

Jeopardize national security.

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Case 3:22-cr-00082-DNH Document 4 Filed 04/02/21 Page 2 of 2

Along with the above-described documents, the government is filing a redacted version of the
proposed sealing order, one that has the words “filed under seal” replaced with the words “for public
filing” and has the case caption redacted. The government has no objection to the public filing of this
version of the proposed sealing order.

The government further requests the following:

1) That the government be permitted to disclose the sealed documents to appropriate law
enforcement officials; and

2) That the Court order that the above-described documents remain under seal until further order
of this Court or any court of competent jurisdiction, except that if the document(s) filed under seal
relate solely to a government request for an arrest warrant, that such documents and the warrant be
unsealed upon the arrest of the person to be arrested.

If this Court determines that the above-described document(s) should not be filed under seal,
the government requests that the Court return the document(s) to the government without filing them
publicly.

Dated: April 2, 2021 ANTOINETTE T. BACON
Acting United States Attorney

By: /s/ Andrew D. Beaty
ANDREW D. BEATY
Assistant United States Attorney
Bar Roll No. 701226


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