PETITION TO UNSEAL INDICTMENT AND ORDER
TO THE HONORABLE EDMUND F. BRENNAN, UNITED STATES MAGISTRATE JUDGE:
COMES NOW JEAN M. HOBLER, Assistant United States Attorney for the Eastern District of California, to petition this Court and respectfully represent:
1. That I have presented to the Grand Jury now in session in the City of Sacramento, California, one proposed indictment charging the above named defendants with violation of:
18 U.S.C. § 1349, 18 U.S.C. § 1341, and 18 U.S.C. § 1028A. 2. That the aforesaid indictment has been returned by the Grand Jury to the Court.
3. That the indictment was sealed by order of the Court in order to mitigate the risk of flight of the defendants.
4. That this morning one of the defendants, ANTHONY SALCEDO, was arrested and will be appearing for arraignment this afternoon.
5. That agents are actively looking for a second defendant and believe their efforts, even if not yet resulting in an arrest, have likely apprised that defendant that he is being sought for arrest on criminal charges.
6. The third defendant is believed to be out of state and so any benefit from further sealing is unlikely to be significant as to that defendant.
As a result, there is no apparent need for the indictment or any related filings to remain sealed. Accordingly, the United States asks that the Court order that the indictment and any related filings be unsealed.
DATED: August 25, 2011 BENJAMIN B. WAGNER United States Attorney By: /s/ Jean Hobler JEAN HOBLER Assistant U.S. Attorney
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