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Case 1:18-cr-00218-TSC Document 71-1 Filed 12/14/18 Page 1 of 3

UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA : CRIMINAL NO. 18-CR-218 (TSC)


:
v. :
:
MARIIA BUTINA, also known as, :
MARIA BUTINA, :
:
Defendant. UNDER SEAL

MOTION FOR LEAVE TO FILE UNDER SEAL

The United States of America, by and through its attorney, the United States Attorney for

the District of Columbia, respectfully moves this Court for leave to file under seal its Motion for

Authorization of Transportation in the above-referenced case. The motion discusses a pending

criminal investigation and matters occurring between the parties that should not appear in the

public record. Although the fact of defendant Butina’s cooperation is now public, the details of

her transportation to-and-from the jail are not. The disclosure of such information would pose a

risk to the defendant’s safety and the safety of the community. Once disclosed, such information

could be used by individuals or entities who might seek to harm or intimidate the defendant to

prevent her from continuing to cooperate with law enforcement. As such, disclosure of this

motion or any related papers may jeopardize defendant’s safety and may jeopardize the ongoing

investigation.

In addition, the proposed order references defendant Butina’s possible transportation to a

grand jury. The fact of her testimony before a grand jury is protected under Rule 6(e) of the

Federal Rules of Criminal Procedure and should remain confidential.


Case 1:18-cr-00218-TSC Document 71-1 Filed 12/14/18 Page 2 of 3

Accordingly, the government hereby requests leave of the Court to file the above-

referenced motion and any related documents under seal.

Respectfully submitted,

JESSIE K. LIU
United States Attorney
D.C. Bar No. 472845

By: /s/
THOMAS N. SAUNDERS
Assistant United States Attorney
N.Y. Bar No. 4876975
United States Attorney’s Office
555 Fourth Street, N.W.
Washington, D.C. 20530
Telephone: 202-252-7790
Email: Thomas.Saunders@usdoj.gov

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Case 1:18-cr-00218-TSC Document 71-1 Filed 12/14/18 Page 3 of 3

UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA : CRIMINAL NO. 18-CR-218 (TSC)


:
v. :
:
MARIIA BUTINA, also known as, :
MARIA BUTINA, :
:
Defendant. UNDER SEAL

ORDER

Based on the representations set forth in the Motion for Leave to File Under Seal the

Government’s Motion for Authorization of Transportation, the Court hereby orders that such

motion is hereby granted, and the government’s referenced pleading and any related documents

shall be filed under seal, including the instant Order and the government’s motion seeking leave

to file under seal.

______________________________________
DATE TANYA S. CHUTKAN
UNITED STATES DISTRICT COURT JUDGE