MOTION TO BE FILED UNDER SEAL

KENNETH S. McHARGH, Magistrate Judge.

MOTION TO SEAL COMPLAINT AND AFFIDAVIT

Now comes the United States of America, by and through counsel, Carole S. Rendon, United States Attorney, and Matthew W. Shepherd, Assistant United States Attorney, and respectfully moves this Court for an order sealing the attached Complaint and Affidavit of Special Agent Shawn S. Hare in the above captioned case for the following reasons: the defendant is currently located in Charlotte, North Carolina. Should the defendant learn of the complaint filed against him, he could reasonably be expected to flee and/or destroy evidence.

The government further requests this Court to order that an Assistant United States Attorney of the Criminal Division of the United States Attorney's Office for the Northern District of Ohio may obtain, upon request, a certified copy of the complaint and affidavit should the defendant be located in another judicial district and a certified copy of this complaint and affidavit is needed for forwarding to that judicial district. See Rule 6(e)(4) of the Federal Rules of Criminal Procedure. Further, the government requests that the sealing order state that the complaint and affidavit are to be unsealed upon the arrest of the defendant.

ORDER TO BE FILED UNDER SEAL

ORDER TO SEAL COMPLAINT AND AFFIDAVIT

Upon good cause shown, IT IS HEREBY ORDERED that the Complaint and Affidavit in the above-captioned case, all documents relating thereto, and this Order be sealed and placed in the custody of the Clerk of Courts.

IT IS FURTHER ORDERED that upon the arrest of the defendant named in the complaint, all documents relating thereto, and this ORDER be unsealed.

IT IS FURTHER ORDERED that an Assistant United States Attorney of the Criminal Division of the United States Attorney's Office for the Northern District of Ohio may obtain, upon request and upon the arrest of the defendant, a certified copy of this complaint should the defendant be located in another judicial district and a certified copy of this complaint is needed for forwarding to that judicial district.