Case 1:18-cr-00111-CMH Document 22 Filed 04/17/19 Page 1 of 3 PageID# 87

IN THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES OF AMERICA
v.
JULIAN PAUL ASSANGE,
Defendant.

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No. 1:18-cr-111

MOTION TO UNSEAL
The United States, through undersigned counsel, hereby moves to unseal the docket in the
above-captioned case and specific filings therein. Specifically, the government requests that the
following documents be unsealed:
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Dkt. No. 6 – Order Granting Motion to Seal
Dkt. No. 12 – Motion to Seal by the United States
Dkt. No. 13 – Order Granting Motion to Seal
Dkt. No. 16 – Notice filed by the United States
Dkt. No. 17 – Motion to Unseal by the United States
Dkt. No. 18 – Order Granting Motion to Unseal
Dkt. No. 20 – Motion to Unseal by the United States

The government requests that the Motion to Seal filed on December 21, 2017 (Dkt. No.
5), remain under seal because it contains nonpublic information about an ongoing criminal
investigation. Premature disclosure of the information could jeopardize the investigation. See In
re Knight Publ’g Co., 743 F.2d 231, 235 (4th Cir. 1984) (“The trial court has supervisory power
over its own records and may, in its discretion, seal documents if the public’s right of access is
outweighed by competing interests.”). The government instead will file a version of this Motion
to Seal that redacts the sensitive information with the Clerk’s Office for public docketing.

 Case 1:18-cr-00111-CMH Document 22 Filed 04/17/19 Page 2 of 3 PageID# 88

The government also requests that the Redacted Criminal Case Cover Sheet filed on
December 21, 2017 (Dkt. No. 4), and the Redacted Criminal Case Cover Sheet filed on March 6,
2018 (Dkt. No. 11), remain under seal because they contain a portion of the defendant’s address
at the time. See Fed. R. Crim. 49.1. The government will file versions of these documents that
redact the address with the Clerk’s Office for public docketing.
For the foregoing reasons, the government requests that the Court enter the attached
order granting this Motion to Unseal.

Respectfully submitted,
G. Zachary Terwilliger
United States Attorney
By:

_______/s/__________________
Thomas W. Traxler
Assistant United States Attorney
United States Attorney’s Office
2100 Jamieson Avenue
Alexandria, VA 22314
Telephone (703) 299-3700
Facsimile (703) 299-3980
Thomas.traxler@usdoj.gov

 Case 1:18-cr-00111-CMH Document 22 Filed 04/17/19 Page 3 of 3 PageID# 89

CERTIFICATE OF SERVICE
I hereby certify that on the 17th day of April, 2019, I electronically filed the foregoing
with the Clerk of Court using the CM/ECF system.

/s/____________________
Thomas W. Traxler
Assistant United States Attorney

 Case 1:18-cr-00111-CMH Document 22-1 Filed 04/17/19 Page 1 of 1 PageID# 90

IN THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES OF AMERICA
v.
JULIAN PAUL ASSANGE,
Defendant.

)
)
)
)
)
)
)

No. 1:18-cr-111

ORDER
This matter comes before the Court on the government’s motion to unseal the docket in the
above-captioned case and specific filings therein. The government’s motion is GRANTED. The
Clerk’s Office shall unseal the docket in this case. The Clerk’s Office shall also unseal the specific
documents in the following docket entries: Dkt. Nos. 6, 12, 13, 16, 17, 18, 20.
The Motion to Seal (Dkt. No. 5), Redacted Criminal Case Cover Sheet (Dkt. No. 4), and
Redacted Criminal Case Cover Sheet (Dkt. No. 11), shall remain under seal, for the reasons stated
in the government’s motion.
The documents filed in all other docket entries shall remain under seal until further order
of the Court.

IT IS SO ORDERED.
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The Honorable Claude M. Hilton
United States District Judge
Alexandria, Virginia
April ____, 2019