Case 1:17-cr-00201-ABJ Document 474 Filed 01/15/19 Page 1 of 2

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
v.

Crim. No. 17-201-1 (ABJ)

PAUL J. MANAFORT, JR.,

Filed Under Seal

Defendant.

GOVERNMENT’S MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL
Pursuant to LCrR 49(f)(6), the United States of America, by and through Special Counsel
Robert S. Mueller, III, hereby requests leave of the Court to file under seal an unredacted version
of the government’s submission in support of its breach determination (Attachment A)
(including its exhibits) and a proposed redacted version, which would be filed publicly
with the Court’s approval.

The government seeks to seal Attachment A (including its

exhibits) and make the redactions reflected in Attachment B and its exhibits because
the

redactions

relate

to

ongoing

law

enforcement investigations

or uncharged

individuals, and public disclosure of certain information in the submission could unduly risk
harming those efforts. See, e.g., Virginia Dep’t of State Police v. Washington Post, 386 F.3d
567, 579 (4th Cir. 2004) (“[A] compelling governmental interest exists in protecting the
integrity of an ongoing law enforcement investigation.”); Washington Post v. Robinson, 935
F.2d 282, 291 (D.C. Cir. 1991) (recognizing that situations where “the release of a plea
agreement may threaten an ongoing criminal investigation” can justify sealing, but finding no
risk of harm on the facts of that case). To preserve the confidentiality of that information,
the government requests that its unredacted submission (Attachment A) (including its
exhibits) be filed under seal, with a redacted version to be submitted

 Case 1:17-cr-00201-ABJ Document 474 Filed 01/15/19 Page 2 of 2

on the public docket after this Court rules on this motion. A proposed order accompanies this
motion.
Respectfully submitted,
ROBERT S. MUELLER III
Special Counsel
Dated: January 14, 2019

By:

/s/ Andrew Weissmann

Andrew Weissmann
Jeannie S. Rhee (D.D.C. Bar No. 464127)
Greg D. Andres (D.D.C. Bar No. 459221)
U.S. Department of Justice
Special Counsel’s Office
950 Pennsylvania Avenue NW Washington,
D.C. 20530
Telephone: (202) 616-0800
Attorneys for the United States of America

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