Opinion
2:23-mj-707-BNW
08-07-2023
UNITED STATES OF AMERICA, Plaintiff, v. ERIC RAMIREZ, aka “DRACO”, Defendant.
JASON M. FRIERSON United States Attorney Nevada Bar No. 7709 BIANCA R. PUCCI Assistant United States Attorney Nevada Bar No. 16129 Attorneys for the United States
APPLICATION TO SEAL
JASON M. FRIERSON United States Attorney Nevada Bar No. 7709 BIANCA R. PUCCI Assistant United States Attorney Nevada Bar No. 16129 Attorneys for the United States
HONORABLE BRENDA N. WERSEER UNITED STATES MAGISTRATE JUDGE
COMES NOW the United States of America, by and through Jason M. Frierson, Acting United States Attorney, and Bianca R. Pucci, Assistant United States Attorney, respectfully moves this Honorable Court for an Order sealing the Complaint, this Application and the Court's Sealing Order, in the above-captioned matter, until such time as this Honorable Court, or another Court of competent jurisdiction, shall order otherwise.
In this case, an order sealing the Complaint would be appropriate because the attached Complaint relates to an ongoing criminal investigation into violations of 18 U.S.C.§§ 922(a)(1)(A), 923(a) and 924(a)(1)(D) - Engaging in the Business of Dealing or Manufacturing Firearms Without a License; 18 U.S.C. §§ 933(a)(1), and 924(d) - Trafficking in Firearms; and 21 U.S.C. §§ 841(a)(1) and (b)(1)(C) - Distribution of a Controlled Substance, that is neither public nor known to all of the targets of the investigation, and its disclosure may alert the targets to the ongoing investigation. Accordingly, there is reason to believe that the disclosure of the information contained within the Complaint will jeopardize the investigation, including by giving additional targets an opportunity to flee or continue flight from prosecution, destroy or tamper with evidence, change patterns of behavior, or notify confederates.
ORDER TO SEAL
Based on the pending Application of the Government, and good cause appearing therefor, IT IS HEREBY ORDERED that the Complaint, the Government's Application and this Court's Sealing Order, in the above-captioned matter shall be sealed until further Order of the Court.