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

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21

PAUL K. CHARLTON United States Attorney District of Arizona LARRY W SZALEK State of W isconsin Bar No. 1003722 MARK T. ODULIO District of Maryland Bar No. 26348 Trial Attorneys 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. 1. John J. Rizzo; 2. Carol A. Rizzo; Defendants. Government's Amended Motion to Permanently Unseal Judgement in a Criminal Case CR03-00345-PHX-ROS

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

22 23 24 25 America v. John J. Rizzo. 26 27 28
1565173.1

files its amended Motion to Permanently Unseal the following matters as set forth below: · Judgement in a Criminal Case entered December 5, 2005 in United States of

Case 2:03-cr-00345-ROS

Document 274

Filed 02/27/2006

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

·

Judgement in a Criminal Case entered December 5, 2005 in United States of America v. Carol Ann Rizzo.

In support of its motion, the government provides the following: 1. As part of the above referenced Judgements, each defendant was ordered by

this Court to cooperate with the Internal Revenue Service (IRS) and pay all tax liabilities. 3. The IRS requires the above referenced Judgements to move forward with its

collection of civil tax liabilities of defendants JOHN RIZZO and CAROL RIZZO. 4. Therefore, the government respectfully moves the court to permanently unseal

the two Judgements as described above. 5. Undersigned counsel discussed this matter with Defense Counsel Alan Caplan

who has no objections to the permanent unsealing of the two Judgements referenced in this motion. Respectfully submitted this 27th day of February, 2006. /s/ LARRY J. WSZALEK MARK T. ODULIO Trial Attorneys United States Department of Justice Tax Division
I hereby certify that on February 27, 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: Alan P. Caplan 630 Carolina St. San Francisco, CA 94107 ([email protected])

2

1565173.1

Case 2:03-cr-00345-ROS

Document 274

Filed 02/27/2006

Page 2 of 2