Motion for Leave to Electronically File under Seal — No. 6:22-cr-00001 (Dkt. 40, M.D. Fla.)
Summary
A motion for leave to electronically file under seal in United States of America v. Tomas Ziupsnys, Case No. 6:22-cr-00001-ACC-GJK, U.S. District Court for the Middle District of Florida, Orlando Division, filed May 10, 2022 as Document 40 by the defendant's counsel at NeJame Law, Joseph Flynn and Chelsea Simmons. It asks the court to seal the defendant's supplement, or addendum, to his sentencing memorandum and motion for a downward variance, with attachments, because the memorandum references information of a sensitive nature that could compromise the safety of the defendant and his family. The certificate of service states that it was filed through CM/ECF with notice to Assistant United States Attorney Emily Chang.
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UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
Case No. 6:22-cr-00001-ACC-GJK
v.
SEALED DOCUMENT
TOMAS ZIUPSNYS,
Defendant.
MOTION FOR LEAVE TO ELECTRONICALLY FILE UNDER SEAL
COMES NOW, the Defendant, TOMAS ZIUPSNYS, by and through his undersigned
counsel of record, and request that this Honorable Court enter an Order Sealing the Defendant’s
Supplement to the Defendant’ Tomas Ziupsnys’s Sentencing Memorandum and Motion for a
Downward Variance for the reasons set forth below:
1. Defendant’s Sentencing Memorandum and Request for a Downward Variance
references information of a sensitive nature and could compromise the Defendant and
his family’s safety based on information contained therein.
WHEREFORE, counsel for the Defendant respectfully requests that this Court enter an
Order Sealing the Defendant’s Addendum to the Sentencing Memorandum and Request for a
Downward Variance along with Attachments for those reasons stated hereinabove.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on May 10, 2022, I electronically filed the foregoing, with
the Clerk of the Court, by using the CM/ECF system, which will send a Notice of Electronic
Filing to the following: Assistant United States Attorney(s), Emily Chang, Office of the United
States Attorney, 400 W. Washington St., Suite 300, Orlando, FL 32805.
NeJame Law, P.A.
189 South Orange Avenue
Suite 1800
Orlando, Florida 32801
Office: 407-500-0000
Attorneys for Defendant
/s/ Joseph Flynn
Joseph Flynn
Florida Bar Number: 47027
Primary Email: trey@nejamelaw.com
Secondary Email: jessica@nejamelaw.com
/s/ Chelsea Simmons
Chelsea Simmons
Florida Bar Number: 57267
Primary Email: chelseas@nejamelaw.com
Secondary Email: lisa@nejamelaw.com
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