Pandemic Darlings The pandemic economy, in original documents
Home Source documents Motion to File Exhibits to the Government's Omnibus Motions in Limine Under Seal (D. Md., Dkt. 205)

Motion to File Exhibits to the Government's Omnibus Motions in Limine Under Seal (D. Md., Dkt. 205)

Summary

A motion filed September 19, 2025 in United States v. Donna Jones, Criminal No. JRR-22-0248, in the U.S. District Court for the District of Maryland, Document 205. The United States asks leave to file its exhibits to the Government's Omnibus Motions in Limine under seal. The motion states that the exhibits contain sensitive information, that no reasonable alternative to sealing is available, and that redaction would render the documents substantially unreadable. It states that counsel will file a hard copy with the Court under Standing Order 2025-04 and intends to serve defense counsel with copies. The motion is signed /s/ Evelyn Lombardo Cusson, and the signature block also names Kelly O. Hayes and John D'Amico.

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

Cite this document

“Motion to File Exhibits to the Government's Omnibus Motions in Limine Under Seal (D. Md., Dkt. 205).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-22-cr-00248-dkt-205-d-md-4088cad4b3/, SHA-256 85ffe014f10b50958493af631258a478c2d24a6e21530858269099b52aa58ec9.

Full text

       Case 1:22-cr-00248-JRR          Document 205        Filed 09/19/25     Page 1 of 2



                       IN THE UNITED STATES DISTRICT COURT
                          FOR THE DISTRICT OF MARYLAND

 UNITED STATES OF AMERICA                       *
                                                *
                v.                              *       CRIMINAL NO. JRR-22-0248
                                                *
 DONNA JONES                                    *
                                                *
                                                *
                                *******
                    MOTION TO FILE EXHIBITS TO THE
            GOVERNMENT’S OMNIBUS MOTIONS IN LIMINE UNDER SEAL

       The United States of America, by and through undersigned counsel, hereby files this

motion to file its exhibits to the Government’s Omnibus Motions in Limine (the “Exhibits”) under

seal. In support of this motion, the government states as follows:

       1.      The Exhibits contains sensitive information and no reasonable alternative to sealing

is available. Specifically, redaction of sensitive portions of the Exhibits would render the

documents substantially unreadable and would compromise counsel’s ability to convey important

information relevant to this case. Additionally, the interests in sealing outweigh the interests of

disclosure on the docket. See Baltimore Sun Co. v. Goetz, 886 F.2d 60, 63 (4th Cir. 1989)

(describing standards for sealing)

       2.      Counsel will file a hard copy of the Exhibits with the Court (pursuant to Standing

Order 2025-04) and intends to serve defense counsel with copies of the Exhibits in compliance

with Fed. R. Crim. P. 49(a)(3)(B) or (a)(4).
        Case 1:22-cr-00248-JRR         Document 205        Filed 09/19/25      Page 2 of 2



        WHEREFORE, the Government respectfully requests that the Court grant the

Government’s Motion to File its exhibits to the Government’s Omnibus Motions in Limine Under

Seal.

                                                     Respectfully submitted,

                                                     Kelly O. Hayes
                                                     United States Attorney

                                                     /s/
                                                     Evelyn Lombardo Cusson
                                                     John D’Amico
                                                     Assistant United States Attorneys
                                                     36 South Charles Street
                                                     Baltimore, Maryland 21201




                                CERTIFICATE OF SERVICE

        I hereby certify that I filed the foregoing with the Court via CM/ECF, which sent a copy to

counsel of record.


                                                     ______/s____________________
                                                     Evelyn Lombardo Cusson
                                                     Assistant United States Attorney




                                                 2

File and source

File
205.pdf
Size
148,418 bytes
SHA-256
85ffe014f10b50958493af631258a478c2d24a6e21530858269099b52aa58ec9
Our copy
205.pdf
Original
No public link identified.
Back to top