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Government’s Motion and Supporting Brief to Seal Indictment and Arrest Warrants — No. 5:25-cr-20543 (Dkt. 4, E.D. Mich.)

Summary

A government motion and supporting brief to seal the indictment and arrest warrants in United States of America v. Cemhan "Jimmy" Biricik and Dr. Martin Perlin, Case 5:25-cr-20543-JEL-KGA, U.S. District Court for the Eastern District of Michigan, Southern Division, filed July 22, 2025 as ECF No. 4. Citing Rule 6(e)(4) of the Federal Rules of Criminal Procedure, the government states that the indictment charges the defendants with one or more federal crimes and asks that it and the arrest warrants be sealed because the defendants may attempt to flee, destroy evidence or intimidate witnesses if the indictment becomes public before they are arrested. It is signed by Assistant United States Attorney Regina R. McCullough for United States Attorney Jerome F. Gorgon, Jr., and carries a so-ordered line for Magistrate Judge Anthony P. Patti.

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‘ Case 5:25-cr-20543-JEL-KGA ECF No. 4, PagelD.31 Filed 07/22/25 Page 1 of 2

ORIGINAL

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

United States of America,

Plainti ff, Case: 5:25-cr-20543
Assigned To : Levy, Judith E.

Referral Judge: Altman, Kimberly G,
Assign. Date : 7/22/2025

Vv. Description: SEALED MATTER
(LLH)
D-1 Cemhan “Jimmy” Biricik,
D-2 Dr. Martin Perlin
Defendants.
/

GOVERNMENT’S MOTION AND SUPPORTING BRIEF
TO SEAL INDICTMENT AND ARREST WARRANTS

The United States of America hereby moves for an order sealing the Indictment
and Arrest Warrants in this case and states:
1. The indictment in this case charges the Defendants with one or more federal
crimes.
2. Rule 6(e)(4) of the Federal Rules of Criminal Procedure provides:

(4) Sealed Indictment. The magistrate judge to whom an indictment is
returned may direct that the indictment be kept secret until the defendant is
in custody or has been released pending trial. The clerk must then seal the
indictment, and no person may disclose the indictment’s existence except as
necessary to issue or execute a warrant or summons.

Fed.R.Crim.P. 6(e)(4).

3. The government requests that the Indictment and Arrest Warrants be sealed

because it is concerned that the Defendants may attempt to flee, destroy

a
Case 5:25-cr-20543-JEL-KGA ECF No. 4, PagelD.32 Filed 07/22/25 Page 2 of 2

evidence, or intimidate witnesses if the Indictment becomes a matter of
public record before the Defendants are arrested.
WHEREFORE, the government requests this Court to issue an order

sealing the Indictment and Arrest Warrants.

Respectfully submitted,

JEROME F. GORGON, Jr.
United States Attorney

s/Regina McCullough

REGINA R. McCULLOUGH
Assistant United States Attorney
211 W. Fort Street, Suite 2001
Detroit, MI 48226
regina.mccullough@usdoj.gov
(313) 226-9618

Dated: July 22, 2025

IT IS SO ORDERED.

Hon. Anthony P. Patti
United States Magistrate Judge

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