Case 1:19-cr-00286-AMD Document 1 Filed 06/20/19 Page 1 of 17 PageID #: 1

FILED

IN CLERK'S OFFICE

US DISTRICT COURT E.D.N.Y.

* JUN 2 0 20I9

EAG/NS/MCM
F. #2019R00029

BROOKLYN OFFICE

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
-

X

INDICTMENT

UNITED STATES OF AMERICA

CR

- against -

Cr.N

(T. 18, U.S.C., §§ 1962(c), 1963,
2421(a), 2422(a),2 and 3551 ^^.)

ROBERT SYLVESTER KELLY,

also known as "R. Kelly,"
Defendant.
X

GOLD, M.J.
THE GRAND JURY CHARGES:
INTRODUCTION

At all times relevant to this Indictment, unless otherwise indicated:
The Enterprise

1.

The defendant ROBERT SYLVESTER KELLY,also known as

"R. Kelly," and individuals who served as managers, bodyguards, drivers, personal assistants
and runners for KELLY,as well as members of KELLY's entourage, comprised an

enterprise (the "Enterprise") within the meaning of 18 U.S.C. § 1961(4), that is, the

Enterprise constituted a group of individuals associated in fact that was engaged in, and the
activities of which affected, interstate and foreign commerce. The Enterprise constituted an

ongoing organization whose members functioned as a continuing unit for a common purpose
of achieving the objectives ofthe Enterprise.

2.

★

The purposes ofthe Enterprise were to promote R. Kelly's music and

the R. Kelly brand and to recruit women and girls to engage in illegal sexual activity with

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KELLY. By promoting R. Kelly's music and the R. Kelly brand, the members ofthe

Enterprise expected to receive financial opportunities and personal benefits, including

increased power and status within the Enterprise.
3.

In connection with the Enterprise, KELLY and other members ofthe

Enterprise traveled throughout the United States and abroad to perform at concert venues,to

promote the R. Kelly brand and to recruit women and girls to engage in illegal sexual activity
with KELLY.

4.

When KELLY attended and performed at concerts and other events,

KELLY and/or members of the Enterprise on KELLY's behalf invited women and girls

backstage and to other events following KELLY's live performances. These women and

girls were often offered wristbands that signified that they were authorized to attend an
event. There, KELLY relied upon members ofthe Enterprise to ensure that only those
authorized to attend were allowed at the event and to manage the flow of women and girls
who were directly interacting with KELLY.
5.

When KELLY identified a woman or girl who he wished to see again,

he either gave his contact information to the woman or girl or obtained her contact
information or relied upon members ofthe Enterprise to do so. Following these events,
KELLY communicated with certain of these women and girls by telephone, including

through the use oftraditional telephone calls, text messages, iMessages and FaceTime. As

part ofthis communication, KELLY often requested that the women and girls provide him
with photographs ofthemselves.
6.

KELLY and other members ofthe Enterprise also arranged for the

women and girls to travel to see KELLY on occasion, including at concerts throughout the

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United States and related events. To facilitate their travel, KELLY directed the women and

girls to contact a member ofthe Enterprise, who then arranged travel for the women and
girls. When the women and girls arrived at the lodging, which was typically selected by a
member ofthe Enterprise, a member ofthe Enterprise usually provided them with
instructions. In addition, members ofthe Enterprise took steps to ensure that the women and

girls did not interact with other women and girls whom KELLY planned to see. Members
ofthe Enterprise then arranged for the women and girls to attend his concerts and positioned
them such that KELLY could see them during his concerts.
7.

KELLY promulgated numerous rules that many of his sexual partners

were required to follow, including the following:

(a)

The women and girls were not permitted to leave their room

without receiving permission from KELLY,including to eat or go to the bathroom;
(b)

The women and girls were required to wear baggy clothing

when they were not accompanying KELLY to an event or unless otherwise instructed by
KELLY;

(c)

The women and girls were not permitted to look at other men

and instead were told to keep their heads down; and

(d)
8.

The women and girls were required to call KELLY "Daddy."

The Enterprise operated within the Eastern District of New York and

elsewhere, including overseas.
Methods and Means of the Enterprise

9.

Among the means and methods by which KELLY and his associates

participated in the conduct ofthe affairs ofthe Enterprise were the following:

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(a)

Committing, attempting and aiding and abetting the commission

of crimes, conspiring to commit crimes, including but not limited to engaging in sexual
activity with girls under 18 years old, engaging in and facilitating sexual activity without
disclosing a sexually transmitted disease KELLY had contracted and producing child
pornography;

(b)

Demanding absolute commitment to KELLY and not tolerating

(c)

Obtaining sensitive information about members and associates

dissent;

ofthe Enterprise to maintain control over them;
(d)

Recruiting and grooming sexual partners for KELLY;and

(e)

Isolating women and girls from friends and family and making

them dependent on KELLY for their financial wellbeing.
The Defendant

10.

The defendant ROBERT SYLVESTER KELLY was the leader of the

Enterprise.
COUNT ONE

(Racketeering)

11.

The allegations contained in paragraphs one through 10 are realleged

and incorporated as if fully set forth in this paragraph.
12.

In or about and between January 1999 and the present, both dates being

approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendant ROBERT SYLVESTER KELLY,also known as "R. Kelly," together with others,

being a person employed by and associated with the Enterprise, an enterprise that engaged in.

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and the activities of which affected, interstate and foreign commerce, did knowingly and
intentionally conduct and participate, directly and indirectly, in the conduct ofthe affairs of

the Enterprise through a pattern of racketeering activity, as defined in Title 18, United States
Code, Sections 1961(1) and 1961(5), consisting ofthe racketeering acts set forth below.
Racketeering Act One

(Sexual Exploitation of a Child - Jane Doe #1)
13.

In or about and between May 1999 and October 15, 1999, both dates

being approximate and inclusive, within the Northern District of Illinois, the defendant
ROBERT SYLVESTER KELLY,together with others, did knowingly and intentionally

employ, use, persuade, induce, entice and coerce a minor, to wit: Jane Doe #1, an individual
whose identity is known to the Grand Jury, to engage in sexually explicit conduct for the

purpose of producing one or more visual depictions of such conduct, which visual depictions
were produced using materials that had been mailed, shipped and transported in interstate

and foreign commerce,in violation of Title 18, United States Code, Sections 2251(a) and
2251(e).
Racketeering Act Two

(Kidnapping - Jane Doe #2)
14.

In or about and between 2003 and 2004, both dates being approximate

and inclusive, within the Northern District of Illinois and elsewhere, the defendant ROBERT
SYLVESTER KELLY,together with others, did knowingly and intentionally secretly
confine an individual, to wit: Jane Doe #2, an individual whose identity is known to the

Grand Jury, against her will, and induce Jane Doe #2 by deceit and enticement to go from
one place to another with intent secretly to confine her against her will, in violation of
Illinois Criminal Code Sections 5/10-1 and 5/5-1.

 Case 1:19-cr-00286-AMD Document 1 Filed 06/20/19 Page 6 of 17 PageID #: 6

Racketeering Act Three

(Mann Act Violation - Jane Doe #2)
15.

The defendant ROBERT SYLVESTER KELLY committed the

following acts, either one of which alone constitutes Racketeering Act Three:
A.

Transportation

16.

In or about and between 2003 and 2004, both dates being approximate

and inclusive, within the Northern District of Illinois and elsewhere, the defendant ROBERT

SYLVESTER KELLY,together with others, did knowingly and intentionally transport an
individual, to wit: Jane Doe #2, in interstate commerce, with intent that such individual

engage in sexual activity for which a person can be charged with a criminal offense, to wit:
violations of Illinois Criminal Code Sections 5/12-16(a)(6)(effective 2002)(aggravated

criminal sexual abuse), 5/12-16(a)(7)(effective 2002)(aggravated criminal sexual abuse)

and 5/12-15(a)(2)(effective 2000)(criminal sexual abuse), in violation of Title 18, United
States Code, Sections 2421(a)and 2.
B.

Coercion and Enticement

17.

In or about and between 2003 and 2004, both dates being approximate

and inclusive, within the Northern District ofIllinois and elsewhere, the defendant ROBERT

SYLVESTER KELLY,together with others, did knowingly and intentionally persuade,
induce, entice and coerce an individual, to wit: Jane Doe #2, to travel in interstate commerce,

to engage in sexual activity for which a person can be charged with a criminal offense, to
wit: violations of Illinois Criminal Code Sections 5/12-16(a)(6)(effective 2002)(aggravated

criminal sexual abuse), 5/12-16(a)(7)(effective 2002)(aggravated criminal sexual abuse)

 Case 1:19-cr-00286-AMD Document 1 Filed 06/20/19 Page 7 of 17 PageID #: 7

and 5/12-15(a)(2)(effective 2000)(criminal sexual abuse), in violation of Title 18, United
States Code, Sections 2422(a) and 2.
Racketeering Act Four

(Mann Act- Jane Doe #3)
18.

In or about and between May 2009 and January 2010, both dates being

approximate and inclusive, within the Northern District ofIllinois and elsewhere, the
defendant ROBERT SYLVESTER KELLY,together with others, did knowingly and

intentionally persuade, induce, entice and coerce an individual who had not attained the age

of 18 years, to wit: Jane Doe #3, an individual whose identity is known to the Grand Jury, to

engage in sexual activity for which a person can be charged with a criminal offense, to wit:
violations of Illinois Criminal Code Section 5/12-16(d)(effective 2002)(aggravated criminal

sexual abuse), using one or more facilities and means of interstate commerce, in violation of
Title 18, United States Code, Sections 2422(b) and 2.
Racketeering Act Five

(Forced Labor- Jane Doe #3)

19.

In or about and between May 2009 and January 2010, both dates being

approximate and inclusive, within the Northern District of Illinois and elsewhere, the
defendant ROBERT SYLVESTER KELLY,together with others, did knowingly and

intentionally obtain the labor and services of a person, to wit: Jane Doe #3, by means of
force, threats offorce, physical restraint and threats of physical restraint to that person or

another person; by means of serious harm and threats ofserious harm to that person or
another person; and by means of a scheme, plan and pattern intended to cause such person to

believe that, ifthat person did not perform such labor and services, such person would suffer

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serious harm and physical restraint, and a combination of such means, in violation of Title
18, United States Code, Sections 1589(a) and 2.
Racketeering Act Six

(Sexual Exploitation of a Child - Jane Doe #3)
20.

In or about and between May 2009 and January 2010, both dates being

approximate and inclusive, within the Northern District of Illinois and elsewhere, the
defendant ROBERT SYLVESTER KELLY,together with others, did knowingly and

intentionally employ, use, persuade, induce, entice and coerce a minor, to wit: Jane Doe #3,
to engage in sexually explicit conduct for the purpose of producing one or more visual
depictions ofsuch conduct, which visual depictions were produced using materials that had
been mailed, shipped and transported in and affecting interstate and foreign commerce, in
violation of Title 18, United States Code, Sections 2251(a), 2251(e) and 2.
Racketeering Act Seven

(Mann Act- Jane Doe #4)
21.

The defendant ROBERT SYLVESTER KELLY committed the

following acts, any one of which alone constitutes Racketeering Act Seven:
A.

Transportation

. 22.

In or about July 2015, within the District of Connecticut, the defendant

ROBERT SYLVESTER KELLY,together with others, did knowingly and intentionally

transport an individual, to wit: Jane Doe #4, an individual whose identity is known to the
Grand Jury, in interstate commerce, with intent that such individual engage in sexual activity
for which a person can be charged with a criminal offense, to wit: violations of Connecticut
General Statutes Sections 53a-71(a)(4)(sexual assault in the second degree) and 53a-

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71(a)(10)(sexual assault in the second degree), in violation of Title 18, United States Code,
Sections 2421(a) and 2.
B.

Coercion and Enticement

23.

In or about July 2015, within the District of Connecticut, the defendant

ROBERT SYLVESTER KELLY,together with others, did knowingly and intentionally

persuade, induce, entice and coerce an individual, to wit: Jane Doe #4, to travel in interstate
commerce, to engage in sexual activity for which a person can be charged with a criminal
offense, to wit: violations of Connecticut General Statutes Sections 53a-71(a)(4)(sexual

assault in the second degree) and 53a-71(a)(10)(sexual assault in the second degree), in
violation of Title 18, United States Code, Sections 2422(a) and 2.
C.

Coercion of Minor

24.

In or about July 2015, within the District of Connecticut, the defendant

ROBERT SYLVESTER KELLY,together with others, did knowingly and intentionally

persuade, induce, entice and coerce an individual who had not attained the age of 18 years, to
wit: Jane Doe #4, to engage in sexual activity for which a person can be charged with a
criminal offense, to wit: violations of Connecticut General Statutes Sections 53a-71(a)(4)

(sexual assault in the second degree) and 53a-71(a)(10)(sexual assault in the second degree),

using one or more facilities and means ofinterstate commerce, in violation of Title 18,
United States Code, Sections 2422(b) and 2.
D.

Transportation of Minors

25.

In or about July 2015, within the District of Connecticut, the defendant

ROBERT SYLVESTER KELLY,together with others, did knowingly and intentionally

transport an individual who had not attained the age of 18 years, to wit: Jane Doe #4, in

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10

interstate commerce with intent that the individual engage in sexual activity for which a
person can be charged with a criminal offense, to wit: violations of Connecticut General
Statutes Sections 53a-71(a)(4)(sexual assault in the second degree) and 53a-71(a)(10)

(sexual assault in the second degree), in violation of Title 18, United States Code, Sections
2423(a) and 2.
Racketeering Act Eight

(Mann Act- Jane Doe #4)
26.

The defendant ROBERT SYLVESTER KELLY committed the

following acts, any one of which alone constitutes Racketeering Act Eight:
A.

Transportation
27.

In or about October 2015, within the Northern District of California,

the defendant ROBERT SYLVESTER KELLY,together with others, did knowingly and

intentionally transport an individual, to wit: Jane Doe #4, in interstate commerce, with intent
that such individual engage in sexual activity for which a person can be charged with a
criminal offense, to wit: violations of California Penal Law Section 261.5(a)(rape,
abduction, carnal abuse of a child and seduction), in violation of Title 18, United States
Code, Sections 2421(a) and 2.
B.

Coercion and Enticement

28.

In or about October 2015, within the Northern District of California,

the defendant ROBERT SYLVESTER KELLY,together with others, did knowingly and

intentionally persuade, induce, entice and coerce an individual, to wit: Jane Doe #4,to travel
in interstate commerce,to engage in sexual activity for which a person can be charged with a
criminal offense, to wit: violations of California Penal Law Section 261.5(a)(rape.

 Case 1:19-cr-00286-AMD Document 1 Filed 06/20/19 Page 11 of 17 PageID #: 11
11

abduction, carnal abuse of a child and seduction), in violation of Title 18, United States
Code, Sections 2422(a) and 2,
C.

Coercion of Minor

29.

In or about October 2015, within the Northern District of California,

the defendant ROBERT SYLVESTER KELLY,together with others, did knowingly and

intentionally persuade, induce, entice and coerce an individual who had not attained the age

of 18 years, to wit: Jane Doe ^#4, to engage in sexual activity for which a person can be
charged with a criminal offense, to wit: violations of California Penal Law Section 261.5(a)
(rape, abduction, carnal abuse of a child and seduction), using one or more facilities and
means of interstate commerce, in violation of Title 18, United States Code, Sections 2422(b)
and 2.

D.

Transportation of Minors
30.

In or about October 2015, within the Northern District of California,

the defendant ROBERT SYLVESTER KELLY,together with others, did knowingly and

intentionally transport an individual who had not attained the age of 18 years, to wit: Jane
Doe #4, in interstate commerce, with intent that such individual engage in sexual activity for

which a person can be charged with a criminal offense, to wit: violations of California Penal
Law Section 261.5(a)(rape, abduction, carnal abuse of a child and seduction), in violation of
Title 18, United States Code, Sections 2423(a) and 2.
Racketeering Act Nine

(Mann Act- Jane Doe #5)
31.

The defendant ROBERT SYLVESTER KELLY committed the

following acts, either one of which alone constitutes Racketeering Act Nine:

 Case 1:19-cr-00286-AMD Document 1 Filed 06/20/19 Page 12 of 17 PageID #: 12
12

A.

Transportation
32.

On or about May 18, 2017, within the Eastern District of New York

and elsewhere, the defendant ROBERT SYLVESTER KELLY,together with others, did

knowingly and intentionally transport an individual, to wit: Jane Doe #5, an individual whose

identity is known to the Grand Jury, in interstate commerce, with intent that such individual

engage in sexual activity for which a person can be charged with a criminal offense, to wit:
violations of New York Penal Law Section 120.20 (reckless endangerment) and New York

Public Health Law Section 2307(exposure of infectious venereal disease), in violation of
Title 18, United States Code, Sections 2421(a) and 2.
B.

Coercion and Enticement

33.

On or about May 18, 2017, within the Eastern District of New York

and elsewhere, the defendant ROBERT SYLVESTER KELLY,together with others, did

knowingly and intentionally persuade, induce, entice and coerce an individual, to wit: Jane
Doe #5, to travel in interstate commerce, to engage in sexual activity for which a person can

be charged with a criminal offense, to wit: violations of New York Penal Law Section 120.20

(reckless endangerment) and New York Public Health Law Section 2307(exposure of
infectious venereal disease), in violation of Title 18, United States Code, Sections 2422(a)
and 2.

Racketeering Act Ten

(Forced Labor- Jane Doe #5)

34.

On or about January 13,2018, within the Central District of California

and elsewhere, the defendant ROBERT SYLVESTER KELLY,together with others, did

knowingly and intentionally obtain the labor and services of a person, to wit: Jane Doe #5, by

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13

means offorce, threats offorce, physical restraint and threats of physical restraint to that
person or another person; by means ofserious harm and threats of serious harm to that

person or another person; and by means of a scheme, plan and pattern intended to cause such

person to believe that, if that person did not perform such labor and services, such person
would suffer serious harm and physical restraint, and a combination ofsuch means, in
violation of Title 18, United States Code, Sections 1589(a) and 2.
Racketeering Act Eleven

(Mann Act- Jane Doe #5)
35.

The defendant ROBERT SYLVESTER KELLY committed the

following acts, either one of which alone constitutes Racketeering Act Eleven:
A.

Transportation

36.

On or about February 2, 2018, within the Eastern District of New York

and elsewhere, the defendant ROBERT SYLVESTER KELLY,together with others, did

knowingly and intentionally transport an individual, to wit: Jane Doe #5, in interstate
commerce, with intent that such individual engage in sexual activity for which a person can

be charged with a criminal offense, to wit: violations of New York Penal Law Section 120.20

(reckless endangerment)and New York Public Health Law Section 2307(exposure of
infectious venereal disease), in violation of Title 18, United States Code, Sections 2421(a)
and 2.

B.

Coercion and Enticement

37.

On or about February 2, 2018, within the Eastern District of New York

and elsewhere, the defendant ROBERT SYLVESTER KELLY,together with others, did

knowingly and intentionally persuade, induce, entice and coerce an individual, to wit: Jane

 Case 1:19-cr-00286-AMD Document 1 Filed 06/20/19 Page 14 of 17 PageID #: 14
14

Doe #5,to travel in interstate commerce, to engage in sexual activity for which a person can
be charged with a criminal offense, to wit: violations of New York Penal Law Section 120.20

(reckless endangerment) and New York Public Health Law Section 2307(exposure of
infectious venereal disease), in violation of Title 18, United States Code, Sections 2422(a)
and 2.

(Title 18, United States Code, Sections 1962(c), 1963 and 3551 et seq.)
COUNT TWO

(Mann Act Transportation - Jane Doe #5)

38.

On or about May 18, 2017, within the Eastern District of New York

and elsewhere, the defendant ROBERT SYLVESTER KELLY,together with others, did

knowingly and intentionally transport an individual, to wit: Jane Doe #5, an individual whose
identity is known to the Grand Jury, in interstate commerce, with intent that such individual

engage in sexual activity for which a person can be charged with a criminal offense, to wit:
violations of New York Penal Law Section 120.20 (reckless endangerment) and New York
Public Health Law Section 2307(exposure of infectious venereal disease).
(Title 18, United States Code, Sections 2421(a),2 and 3551 ^ seq.l
COUNT THREE

(Mann Act Coercion and Enticement- Jane Doe #5)
39.

On or about May 18,2017, within the Eastern District of New York

and elsewhere, the defendant ROBERT SYLVESTER KELLY,together with others, did

knowingly and intentionally persuade, induce, entice and coerce an individual, to wit: Jane
Doe #5,to travel in interstate commerce, to engage in sexual activity for which a person can

be charged with a criminal offense, to wit: violations of New York Penal Law Section 120.20

 Case 1:19-cr-00286-AMD Document 1 Filed 06/20/19 Page 15 of 17 PageID #: 15
15

(reckless endangerment) and New York Public Health Law Section 2307(exposure of
infectious venereal disease).

(Title 18, United States Code, Sections 2422(a), 2 and 3551 ^ seq.)
COUNT FOUR

(Mann Act Transportation - Jane Doe #5)

40.

On or about February 2,2018, within the Eastern District of New York

and elsewhere, the defendant ROBERT SYLVESTER KELLY,together with others, did

knowingly and intentionally transport an individual, to wit: Jane Doe #5, in interstate
commerce, with intent that such individual engage in sexual activity for which a person can

be charged with a criminal offense, to wit: violations of New York Penal Law Section 120.20

(reckless endangerment) and New York Public Health Law Section 2307(exposure of
infectious venereal disease).

(Title 18, United States Code, Sections 2421(a), 2 and 3551 et seq.)
COUNT FIVE

(Mann Act Coercion and Enticement- Jane Doe #5)
41.

On or about February 2, 2018, within the Eastern District of New York

and elsewhere, the defendant ROBERT SYLVESTER KELLY,together with others, did

knowingly and intentionally persuade, induce, entice and coerce an individual, to wit: Jane
Doe #5,to travel in interstate commerce, to engage in sexual activity for which a person can

 Case 1:19-cr-00286-AMD Document 1 Filed 06/20/19 Page 16 of 17 PageID #: 16
16

be charged with a criminal offense, to wit: violations of New York Penal Law Section 120.20
(reckless endangerment) and New York Public Health Law Section 2307(exposure of
infectious venereal disease).

(Title 18, United States Code, Sections 2422(a), 2 and 3551 et seq.)

A TRUE BILL

Myfdj

UA-yYX^

FOREPERSON

\P
RICHARD P. DONOGHUE
UNITED STATES ATTORNE"
EASTERN DISTRICT OF NEW YORK

 Case 1:19-cr-00286-AMD Document 1 Filed 06/20/19 Page 17 of 17 PageID #: 17
F.#: 2019R00029

FORMDBD-34

NO.

JUN.85

UNITED STATES DISTRICT COURT
EASTEIU^ Dwfrzcf o/NEW YORK
CRIMINAL DIVISION

THE UNITED STATES OF AMERICA
V5.

ROBERT SYLVESTER KELLY,
Defendant.

INDICTMENT
(T. 18, U.S.C., §§ 1962(c), 1963, 2421(a), 2422(a), 2 and 3551 et seg.)
A true bill.

Foreperson

Filed in open court this
of

day,
A.D.20

Clerk

Bail, $
Elizabeth Geddes,Assistant U.S. Attorney (718)254-6430

 FILED
Case 1:19-cr-00286-AMD Document 1-1 Filed 06/20/19 Page 1 of 1 PageID
#: 18

IN CLERK'S OFFICE

US DISTRICT COURT E.D.N.Y.

JUN2 0 2019

★

INFORMATION SHEET

BROOKLYN OFFICE
UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK

1.

Title of Case: United States v. Robert S. Kellv

2.

Related Magistrate Docket Number(s):

3.

Arrest Date; Not applicable

4.

Nature of offense(s): IE Felony
□

'

DONNELLY J.

GOLD MJ

Misdemeanor

5.

Related Cases - Title and Docket No(s). (Pursuant to Rule 50.3.2 of the Local
E.D.N.Y. Division of Business Rules):

6.

Projected Length of Trial:

Less than 6 weeks

□

More than 6 weeks

IE

7.

County in which crime was allegedly committed: Queens
(Pursuant to Rule 50.1(d) of the Local E.D.N.Y. Division of Business Rules)

8.

Was any aspect of the investigation, inquiry and prosecution giving rise to the case

pending or initiated before March 10,2012.'

DYes E No

9.

Has this indictment/information been ordered sealed?

E Yes □ No

10.

Have arrest warrants been ordered?

E Yes DNo

11.

Is there a capital count included in the indictment?

DYes E No

RICHARD P. DONOGHUE

United States Attorney
By:
Elizabeth Geddes

Assistant U.S. Attorney
(718) 254-6430

Judge Brodie will not accept cases that were initiated before March 10, 2012.

Rev. 10/04/12

 FILED

Case 1:19-cr-00286-AMD Document
Filed 06/20/19 Page 1 of 2 PageID #: 21
IN CLERK'S1-3
OFFICE

US DISTRICT COURT E.D.N.Y.

TO: Clerk's Office

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK ★

JUN i ® 2019

BROOKLYN OFFICE
APPLICATION FOR LEAVE

TO FILE DOCUMENT UNDER SEAL

A)If pursuant to a prior Court Order:
Docket Number of Case in Which Entered:

Judge/Magistrate Judge:
UNITED STATES V. JOHN DOE

ate

CK

Sites

Docket Number
********************************

DONNELLY Jo BI if a new application,the statute, regulation, or other legal basis that
Defendant

SUBMITTED BY: Plaintiff_

authorizes filing under seal

DOJ ^

Name: Elizabeth Geddes
Firm Name:United States Attorney's Office
Address: 271 Cadman Plaza East
Brooklyn. NY 11201

GOLD, M.L
ORDERED SEALED AND PLACED IN THE CLERK'S OFFICE,

Phone Number: 718-254-6430

AND MAY NOT BE UNSEALED UNLESS ORDERED BY

E-Mail Address:Elizabeth.Geddes@usdoi.gov

THE COURT.

INDICATE UPON THE PUBLIC DOCKET SHEET: YES

NO ✓
DATED: Brooklyn

If yes,state description of document to be entered on docket sheet:

,NEW YORK

June 20,2019/

U.Q. DiaTRICT JUi)€EyU.S. MAGISTRATE JUDGE
RECEIVED IN CLERK'S OFFICE June 20.2019
DATE

MANDATORY CERTIFICATION OF SERVICE:

A.)

A copy ofthis application either has been or will be promptly served upon all parties to this action, B.)

the following other statute or regulation:
(Check one)
June 20,2019
DATE

Service is excused by 31 U.S.C. 3730(b), or by

; or C.) ✓ This is a criminal document submitted, and flight public safety, or security are significant concerns.

SIGNATURE

 Case 1:19-cr-00286-AMD Document 1-3 Filed 06/20/19 Page 2 of 2 PageID #: 22

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