NOTICE TO REQUEST TO SEAL DOCUMENTS: REQUEST TO SEAL DOCUMENT AND PROPOSED ORDER

KIMBERLY J. MUELLER, District Judge.

Mr. Mitchell is currently set for jury trial on March 7, 2016. Mr. Mitchell is requesting to continue the trial date till late June or early July, 2016. The justification for this request requires that counsel expose information covered by the Attorney/Client privilege, Attorney work product and attorney trial strategy. Therefore, counsel is seeking to file his Declaration under seal.

The Requested document to be sealed is entitled DECLARATION UNDER SEAL IN SUPPORT OF MOTION TO CONTINUE JURY TRIAL DATE. This is a declaration of Michael Chastaine, attorney for the defendant Albert Mitchell. This declaration exposes information covered by the Attorney/Client privilege, Attorney work product and attorney trial strategy. This document should not be released to the prosecution in that it would provide an unfair advantage, expose client communications, attorney work product and thought process.

This Notice has been service on counsel for the United States.

Courts generally accept attorney-client privilege and the work-product-doctrine as a "compelling reason" justifying a motion to seal. (See Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 125 (2d Cir. 2006) (stating "attorney-client privilege might well be such a compelling reason" to preserve seal) (Hanson v. Wells Fargo Home Mortg., Inc. (W.D.Wash. Oct. 17, 2013, No. C13-0939JLR) 2013 U.S. Dist. LEXIS 149752, at 6.)

No one other than the court should be permitted to access this document.

ORDER

Good cause appearing, the Court grants Mr. Mitchells Request to Seal the DECLARATION UNDER SEAL IN SUPPORT OF MOTION TO CONTINUE JURY TRIAL DATE. This document shall remain under seal until further order by the Court.