Case 3:12-cr-00317-L Document 111 Filed 04/21/14

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION ___________________________________________ UNITED STATES OF AMERICA v. BARRETT LANCASTER BROWN | | | | | No. 3:12-CR-317-L No. 3:12-CR-413-L No. 3:13-CR-030-L

GOVERNMENTS UNOPPOSED MOTION TO VACATE THE AGREED ORDER RE: EXTRAJUDICIAL STATEMENTS 1 AND TO UNSEAL DOCUMENTS The United States Attorney for the Northern District of Texas, by and through the undersigned Assistant United States Attorney, files this Unopposed Motion to Vacate the Agreed Order Re: Extrajudicial Statements entered in this cause on September 4, 2013, for the reason that the defendant has agreed to plead guilty and waived his right to a jury trial. The government also moves to unseal the following documents sealed pursuant to such order: DOCUMENT Factual Resume Plea Agreement Motion to seal the Plea Agreement and Factual Resume Opposition to Browns Motion to Dismiss the Indictment Motion to Seal Governments Opposition to Browns Motion to Dismiss Governments Opposition to Browns Motion to Dismiss Sealed Order re: Motion to Seal Motion to Seal Governments Opposition to Browns Motion to Dismiss 3:12-CR-317-L 109 108 104 3:12-CR-413-L 76 75 68 3:13-CR-030-L

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1 The Courts September 4, 2013 Agreed Order Re: Extrajudicial Statements is document number 93 in cause number 3:12-CR-317-L , document number 55 in cause number 3:12-CR-413-L, and document number 53 in cause number 3:13-CR-030-L.

Case 3:12-cr-00317-L Document 111 Filed 04/21/14

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Since the defendants anticipated guilty plea will obviate the need for a trial, the government requests this Honorable Court vacate the Agreed Order Re: Extrajudicial Statements entered in this cause on September 4, 2013, and unseal the above referenced documents. Respectfully submitted, SARAH R. SALDAA UNITED STATES ATTORNEY S/ Candina S. Heath CANDINA S. HEATH Assistant United States Attorney State of Texas Bar No. 09347450 1100 Commerce Street, 3rd Floor Dallas, Texas 75242 Tel: 214-659-8600 Fax: 214-767-2846 candina.heath@usdoj.gov CERTIFICATE OF CONFERENCE I hereby certify that on April 18, 2014, I conferred with Barrett Browns attorney, Ahmed Ghappour, who did not oppose the governments Motion to Vacate the Agreed Order Re: Extrajudicial Statements and to Unseal Documents. S/ Candina S. Heath CANDINA S. HEATH Assistant United States Attorney CERTIFICATE OF SERVICE I hereby certify that on April 21, 2014, I electronically filed the foregoing document with the clerk for the U.S. District Court, Northern District of Texas, using the electronic case filing (ECF) system of the court. The ECF system sent a "Notice of Electronic Filing" to Browns attorneys of record Ahmed Ghappour, Charles Swift, and Marlo Cadeddu, who consented in writing to accept this Notice as service of this document by electronic means. S/ Candina S. Heath CANDINA S. HEATH Assistant United States Attorney