Case 1:11-cr-00449-RWT Document 5 Filed 08/29/11 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND UNITED STATES OF AMERICA

v.
STANLEY NEEDLEMAN
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CRIMINAL NO. RWT-II-0449

(Under Seal)
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MOTION TO UNSEAL INFORMATION

The United States of America, by its attorneys, Rod J. Rosenstein,

United States <\ntorn~y ~

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for the District of Maryland, and Sandra Wilkinson and Martin Clarke, Assistant Attorneys, moves this Honorable Court as follows: I.

Unite1t"State-s'

On August 16,20 II, this Office filed an Inforn1ation in the above-captioned

matter

with an accompanying

motion under seal. The grounds for the Motion to Seal were as follows: the

case is of public importance as the Defendant is a practicing criminal defense attorney in Baltimore, Maryland. The government further proffered that it would have been premature to release the filing of these charges which are filed by the United States Attorney prior to the assignment of the case and the scheduling of the initial appearance of the Defendant and the plea proceeding. was granted by Chief Magistrate documents was issued. 2. On or about August 17,2011, Chief Judge Deborah K. Chasanow advised that the recused themselves from this matter and agreed that the ease Judge Paul W. Grimm and an Order temporarily Said Motion sealing the

judges of the Northern Divisionjointly

should be assigned to the Southern Division. The random assignment was thereafter made to Judge Roger W. Titus 3. The parties were advised that Judge Titus was temporarily unavailable but that the

Case 1:11-cr-00449-RWT Document 5 Filed 08/29/11 Page 2 of 2

Initial Appearance Williams, Jr..

and the plea proceeding could proceed forthwith in front of Judge Alexander

The plea proceeding was thereafter and is currently scheduled, with the consent of 1,2011 at 11:30 a.m., United States Courthouse, Greenbelt,

all parties, to be held on September Maryland, Courtroom 4A. 4.

For the foregoing reasons, undersigned counsel respectfully moves this Court for an Information Relative A proposed Order is

Order directing that this Motion, the Information and the related "Defendant to a Criminal Action (known as the "Speedy Trial Form") be UNSEALED. attached for the Court's consideration. Respectfully submitted, Rod J. Rosenstein United States Attorney /s/

Sandra Wilkinson Martin Clarke Assistant United States Attorneys