Case 1:19-mc-00032-ABJ Document 6 Filed 03/19/19 Page 1 of 3

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
IN THE MATTER OF THE APPLICATION OF Misc. Action No. 19-0032 (ABJ)
WP COMPANY LLC

GOVERNMENT’S UNOPPOSED MOTION FOR AN EXTENSION OF TIME IN
WHICH TO FILE A RESPONSE TO THE
MOTION FOR PUBLIC ACCESS TO SEALED COURT RECORDS
The United States of America, by and through Special Counsel Robert S. Mueller, III, files
this unopposed motion for an extension of time—to and including April 1, 2019—to respond to a
motion to unseal certain search warrant materials. The Washington Post does not oppose this
motion.
1. On March 7, 2019, the Washington Post filed a motion under Local Criminal Rule 57.6
for public access to certain unredacted records from United States v. Manafort, No. 17-cr-201ABJ-1. Specifically, the motion seeks unredacted versions of filings and hearing transcripts related
to this Court’s determination of whether Manafort breached his plea agreement, and the
government’s unredacted sentencing submission. The motion additionally asks the Court to put
in place a “process” for ongoing reevaluation of redactions—including a forward looking reporting
obligation for the government and regular reassessment of each redaction. The government’s
response is presently due on March 21, 2019. See L. Cr. R. 47(b).
2. The government respectfully requests an extension of time—through and including
April 1, 2019—to respond to the motion. The counsel responsible for preparing the response face
the press of other work and require additional time to consult within the government.
3. On March 19, 2019, counsel for the Washington Post informed the government that
they do not oppose the requested extension.

 Case 1:19-mc-00032-ABJ Document 6 Filed 03/19/19 Page 2 of 3

For the foregoing reasons, the government’s unopposed motion for an extension of time to
and including April 1, 2019 should be granted. A proposed order accompanies this motion.

Respectfully submitted,
ROBERT S. MUELLER III
Special Counsel
By: /s/
Michael R. Dreeben
Adam C. Jed
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
Dated: March 19, 2019

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 Case 1:19-mc-00032-ABJ Document 6 Filed 03/19/19 Page 3 of 3

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
IN THE MATTER OF THE APPLICATION OF Misc. Action No. 19-0032 (ABJ)
WP COMPANY LLC

[Proposed] ORDER
Upon consideration of the government’s Unopposed Motion for a One-Week Extension of
Time in Which to File a Response to the Motion for Public Access to Sealed Court Records, it is
hereby
ORDERED that the government’s motion is GRANTED.

________________
Date

__________________________________
HON. AMY BERMAN JACKSON
UNITED STATES DISTRICT JUDGE