Free Motion to Unseal Document - District Court of Arizona - Arizona

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PAUL K. CHARLTON United States Attorney District of Arizona MARK T. ODULIO District of Maryland Bar No. 26348 Trial Attorney U.S. Department of Justice Tax Division Two Renaissance Square 40 N. Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 Telephone (602) 514-7661

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, Plaintiff, v. Leslie A. Nix Defendant. Government's Motion to Permanently Unseal Plea Agreement CR04-0045-PHX-LOA

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1803440.1

Plaintiff, United States of America, by and through its counsel of record, Larry J. Wszalek and Mark T. Odulio, Trial Attorneys, Department of Justice, Tax Division, hereby files its Motion to Permanently Unseal the following matter as set forth below: Plea Agreement in United States v. Leslie A. Nix entered on January 26, 2004 (Docket Number 7). In support of its motion, the government provides the following:

Case 2:04-cr-00045-LOA

Document 45

Filed 07/13/2006

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As part of the above referenced plea agreement, the defendant agreed to

cooperate with the Internal Revenue Service (IRS) and pay all tax liabilities. 2. The IRS requires the above referenced plea agreement as part of its collection

of civil tax liabilities of defendant LESLIE ANN NIX. 3. Therefore, the government respectfully moves the court to permanently unseal

the plea agreement as described above. 4. Undersigned counsel discussed this matter with Defense Counsel Dana

Carpenter who has no objections to the permanent unsealing of the plea agreement referenced in this motion. Respectfully submitted this 13th day of July, 2006. /s/ Mark T. Odulio MARK T. ODULIO Trial Attorney United States Department of Justice Tax Division
I hereby certify that on July 13, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF system for filing and transmittal of a Notice of Electronic Filing to the following CM /ECF registrants: Dana Carpenter 3106 N. 16 th St. Phoenix, Arizona 85016 602-266-5770

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1803440.1

Case 2:04-cr-00045-LOA

Document 45

Filed 07/13/2006

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