Case 1:21-cr-00054-DAD-BAM Document 4 Filed 02/25/21 Page 1 of F
2 ILED
1 McGREGOR W. SCOTT
SEALED Feb 25, 2021
CLERK, U.S. DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
United States Attorney
2 ALEXANDRE M. DEMPSEY
JOSEPH D. BARTON
3 Assistant United States Attorneys
2500 Tulare Street, Suite 4401
4 Fresno, CA 93721
Telephone: (559) 497-4000
5 Facsimile: (559) 497-4099
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Attorneys for Plaintiff
7 United States of America
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IN THE UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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UNITED STATES OF AMERICA, CASE NO. 1:21-cr-00054-DAD-BAM
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Plaintiff, MOTION AND PROPOSED ORDER TO
13 SEAL INDICTMENT
v.
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JASON VERTZ, AND
15 ALANA POWERS,
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Defendant.
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19 The government moves the Court, pursuant to Rule 6(e) of the Federal Rules of
20 Criminal Procedure, to order and direct that the Indictment returned by the Grand Jury
21 on February 25, 2021, charging the above defendants with a violation of 18 U.S.C. § 1349 –
22 Conspiracy to Commit Mail Fraud; 18 U.S.C. § 1028A(a)(1) – Aggravated Identity Theft
23 (Two Counts); 18 U.S.C. § 981(a)(1)(C), and 28 U.S.C. § 2461(C) – Criminal Forfeiture, be
24 kept secret until the defendants named in this Indictment are either in custody or have
25 been given bail on these offenses; and further order that until such time as the defendants
26 are in custody or have been given bail, that no person shall disclose the finding of the
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Motion to Seal Indictment 1
Case 1:21-cr-00054-DAD-BAM Document 4 Filed 02/25/21 Page 2 of 2
1 Indictment or any warrant issued pursuant thereto, except when necessary for the
2 issuance and execution of the warrant.
3 DATED: February 25, 2021 Respectfully submitted,
4 McGREGOR W. SCOTT
5 United States Attorney
6 By /s/ ALEXANDRE M. DEMPSEY _____
ALEXANDRE M. DEMPSEY
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Assistant U.S. Attorney
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IT IS SO ORDERED.
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11 Dated: February 25, 2021 _____________________________
STANLEY A. BOONE
12 U.S. Magistrate Judge
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Motion to Seal Indictment 2