Free Motion to Seal - District Court of Connecticut - Connecticut

I Case 3:00-cr-00044-SRU Document 630 Filed 04/09/2007 Page 1 of 3
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA : Civil N0. 3:03—CV—980 (SRU) I
RYAN BALDWIN APRIL 9, 2007
DEFENDANT RYAN BALDWIN’S _
MOTION TO FILE UNDER SEAL
Defendant Ryan Baldwin hereby moves pursuant to Local Rule 5(d) to file under Z
seal his Motion To Reopen Petition For Writ Of I-labeas Corpus Pursuant To 28 U.S.C. l
§2255 ("Motion to Re—Open"), submitted herewith. A redacted version has been filed.
There is good cause to seal the Motion to Re-Open, as follows:
1. Mr. BaIdwin’s Motion to Re-Open attacks the integrity of the underlying
proceedings relative to his original pro se petition under 28 U.S.C. §2255. The petition
was withdrawn in 2004.
2. The Motion to Re—Open includes references to confidential material g
(including attorney-client communications) that are not public. Disclosure of this
confidential material could jeopardize the safety of a potential witness.

Case 3:00-cr-00044-SRU Document 630 Filed 04/09/2007 Page 2 of 3
VVHEREFORE, lVlr. Baldwin respectfully requests that his Motion to Re—Open be
filed under seal.
{Z,&7%Ҥ@
Robert l\/l. Frost, . ct19771)
Zeldes, Needle & Cooper
1000 Lafayette Blvd.
P.O. Box 1740
Bridgeport, Connecticut 06604
Tel: (203) 333-9441
Fax: (203) 333-1489 j
Email: n‘[email protected] -
Attorney for Ryan Baldwin (
l
2

Case 3:00-cr-00044-SRU Document 630 Filed 04/09/2007 Page 3 of 3 I
CERTIFICATION E
This is to certify that a copy of the foregoing has been sent via first class, United Q
‘ States Mail, postage prepaid, on this date, to:
Peter Markle, AUSA ;
l-l. Gordon Hall, AUSA
U.S. Attorneys Office
157 Church Street, 23rd Floor
P.O. Box 1824
New Haven, CT 06510 _
Z Rudolph Flndley Miller, Esq.
390 Centre St.
Jamaica Plain, MA 02130
I Dated at Bridgeport, Connecticut this 9th day of April, 2007.
Robert M. Frost, .
i 3 ·