Free Motion to Seal Document - District Court of Delaware - Delaware

Case 1:07-cr-00093-SLR

Document 49

Filed 05/28/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA,

vs. JONATHAN MCKINNEY Defendant

: : : Case No.: 1:07 CR 00093 SLR : : : :

ORDER AND NOW, this day of , 2008, upon Motion of the Defendant,

Jonathan McKinney, it is hereby ORDERED and DECREED that the Clerk of the United States District Court for the District of Delaware shall place under seal the Sentencing Memorandum filed on behalf of Jonathan McKinney.

By The Court:

____________________________ Sue L. Robinson, J.

Case 1:07-cr-00093-SLR

Document 49

Filed 05/28/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA,

vs. JONATHAN MCKINNEY Defendant

: : : : Case No.: 1:07-CR-00093-SLR : : :

DEFENDANT'S MOTION TO SEAL HIS SENTENCING MEMORANDUM TO THE HONORABLE SUE L. ROBINSON, JUDGE OF THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE: 1. The defendant, Jonathan McKinney, was sentenced on May 19, 2008. 2. A Sentencing Memorandum was filed on behalf of Mr. McKinney, along with exhibits. 3. The Sentencing Memorandum contains highly confidential and personal information and does not serve any purpose by being available to the general public. 4. It would be beneficial to Mr. McKinney and to those whose letters have been attached to the Sentencing Memorandum, and in order to protect

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Case 1:07-cr-00093-SLR

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Filed 05/28/2008

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their privacy, if the Sentencing Memorandum and the attachments were to be sealed. 5. The United States, through the Assistant United States Attorney, Edmond Falgowski, Esq. has no objection to the entry of this Order by the Court. WHEREFORE, the defendant, Jonathan McKinney, respectfully requests that the Court order that the Sentencing memorandum filed on his behalf be sealed.

Respectfully submitted, PERLSTEIN LAW

By: _s//_______________________ Paul M. Perlstein, Esq. Attorney for Defendant, Jonathan McKinney

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