Opinion
Case No. 2:11-00001-5
12-10-2012
UNITED STATES OF AMERICA v. TIMOTHY JAMES NEILL, JR.
Chief Judge Haynes
MOTION TO UNSEAL DOCUMENTS
COMES NOW Defendant, Timothy Neill Jr., by and through his undersigned counsel and respectfully moves this Honorable Court to unseal Docket Entries 435 and 437. In support hereof, Defendant Neill would state as follows:
1. Defendant Neill's date of birth was redacted on the document ultimately filed by the government. (Docket Entry 435). Thus, the need for the document to be under seal no longer exists. The same is true for the Court's Order. (Docket Entry 437).
2. Defendant Neill is not a cooperating witness in this matter, and, due to safety concerns, he does not want the public record to potentially indicate otherwise (sealed filings by the government prior to sentencing are often indicative that a defendant is cooperating or has cooperated).
3. AUSA Brent Hannafan has informed undersigned counsel that he does not object to the document(s) being unsealed.
WHEREFORE, based on the foregoing, Defendant Neill respectfully requests that Docket Entries 435 and 437 be unsealed.