Motion to Seal Complaint and Related Documents - United States v. Lugo and Venant (Document 3)

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A Motion to Seal Complaint and Related Documents in United States of America v. Julio Lugo, a/k/a "Rick Williams," and Rosenide Venant, a/k/a "Rose Lugo," Case No. 8:21-mj-01294-AAS, in the United States District Court for the Middle District of Florida, Tampa Division, Document 3, filed March 26, 2021. The United States, by Karin Hoppmann, Acting United States Attorney, asks the Court to direct the Clerk to seal the Complaint, the file copy of the arrest warrant and the motion, stating that disclosure before the arrest could hinder arrest efforts and compromise an ongoing criminal investigation. It also asks that the documents be unsealed without further order when any named defendant is taken into custody. The signature block names an Assistant United States Attorney.

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Case 8:21-mj-01294-AAS Document3 Filed 03/26/21 Page 1 of 2 PagelD 34

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA

TAMPA DIVISION
UNITED STATES OF AMERICA 8:2 1MJ1294AAS
y CASE NO.

JULIO LUGO, a/k/a “Rick Williams,” and
ROSENIDE VENANT, a/k/a “Rose Lugo”

MOTION TO SEAL COMPLAINT
AND RELATED DOCUMENTS

The United States of America, by Karin Hoppmann, Acting United
States Attorney for the Middle District of Florida, moves the Court to direct
the Clerk to seal the Complaint, the file copy of the arrest warrant, this
motion, the Court’s order regarding this motion, and any other documents
filed in thiscase that would identify the defendant. Disclosure of the existence
of these documents prior to the arrest of the defendant could hinder or
impede arrest efforts and compromise an ongoing criminal investigation.

The United States further moves that the Court direct the Clerk to seal
the Complaint in this case except when necessary to provide certified copies of
the Complaint to the United States Attorney’s Office.

The United States further requests that the Court’s Order allow the
United States Marshals Service to release certified copies of the arrest warrant
to the case agent or other appropriate law-enforcement officers and/or to the

United States Attorney’s Office, upon verbal request of the United States
-. =,, Case 8:21-mj-01294-AAS Document 3

Filed 03/26/21 Page 2 of 2 PagelD 35

Attorney’s Office to the United States Marshals Service, without further order

of the Court.

The United States further requests that the Court’s Order allow the

United States to disclose the existence of the Complaint in any subsequent

search warrants or seizure warrants, which may be executed in conjunction

with the arrest of the defendant, without further order of the Court.

The United States further moves that the Court direct the Clerk to

unseal the documents described herein without further order when any named

defendant is taken into custody.

Respectfully submitted,

KARIN HOPPMANN
Acting United States Attorney

/s/ Kristen A. Fiore

Kristen A. Fiore

Assistant United States Attorney
United States Attorney No. 178
400 N. Tampa Street, Suite 3200
Tampa, Florida 33602-4798
Telephone: (813) 274-6000
Facsimile: (813) 274-6358
E-mail: kristen.fiore@usdoj.gov


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