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Case l:17-cr-00182-RDM Documents Filed 07/28/17 Page 1 of 3 




JUL 2 8 2017 

Clerk, U.S. District & Bankruptcy 
Courts for the District of Columbia 




Criminal No. l:17-mj-53ffj 



The United States, by and through undersigned counsel, asks for an Order sealing the 
criminal complaint and all filings associated with the complaint, including the docket in this 
matter, this Motion to Seal, and the proposed Order, until the United States makes a motion to 
unseal, except as necessary to conduct the defendant’s initial appearance. 

I. Reasons for Sealing the Complaint and Associated Documents 

1. The Court has the inherent power to seal court filings when appropriate, including the 
complaint. See United States v. Hubbard, 650 F.2d 293, 315-16 (D.C. Cir. 1980) (citing Nixon v. 
Warner Communications, Inc., 435 U.S. 589, 598 (1978)). The Court may also seal the complaint 
to prevent serious jeopardy to an ongoing criminal investigation when, as in the present case, such 
jeopardy creates a compelling governmental interest in preserving the confidentiality of the 
Complaint. See Washington Post v. Robinson, 935 F.2d 282, 287-89 (D.C. Cir. 1991). In this case, 
sealing is necessary to avoid possible material prejudice to the ongoing investigation. 

2. Defendant Papadopoulos served as a foreign policy advisor for ihe presidential 
campaign of Donald J. Trump starting no later than on or about March 16, 2016, and continuing 
through most of that campaign. On July 27, 2017, the defendant was arrested when he landed at 
Washington Dulles International Airport on a flight from Munich, Germany. He has been charged 

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Case l:17-cr-00182-RDM Document 3 Filed 07/28/17 Page 2 of 3 

in a criminal complaint filed in this Court with making false statements to agents of the Federal 
Bureau of Investigation, in violation of 18 U.S.C. § 1001; and altering or concealing records, in 
violation of 18 U.S.C. § 1519. The charges are based on actions that the defendant took during 
and after law enforcement interviews with him as part of an investigation into the Russian 
government’s efforts to interfere in the 2016 presidential election. On the morning of July 28, 
2017, the Court granted an oral motion to seal these documents. Cf Local Criminal Rule 49(e)(4) 
(providing that “the filing of every . . . document [prior to the initial appearance of a criminal 
defendant] under seal shall not require a motion to seal”). The Government now moves for an 
equivalent written order. 

3. Premature disclosure of the fact of the defendant’s arrest and the nature of the 
charges against him is likely to substantially prejudice both the defendant and the government. 
Defendant has indicated that he is willing to cooperate with the government in its ongoing 
investigation into Russian efforts to interfere in the 2016 presidential election. Public disclosure 
of the defendant’s initial appearance, however, would significantly undermine his ability to serve 
as a proactive cooperator. In addition, public disclosure of defendant’s arrest and the 
accompanying criminal charges may alert other subjects to the direction and status of the 
investigation. Once alerted to this development, potential targets may be prompted to destroy or 
conceal incriminating evidence, including evidence that the government may be pursuing 
imminently pursuant to judicial authorization. 

4. The United States has considered alternatives less restrictive than sealing, 
including, for example, the possibility of redactions, and has determined that none would suffice 
to avoid potential material prejudice to this investigation. 

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Case l:17-cr-00182-RDM Document 3 Filed 07/28/17 Page 3 of 3 

II. Period of Time That the Government Seeks To Have Matter Remain 

Under Seal. 

5. The government requests that the criminal complaint materials remain sealed until 
the need to maintain the confidentiality of these materials expires, after which time the United 
States will move to unseal the materials. The government will promptly advise the Court if it is 
determined that sealing is no longer required to protect the interests at stake here. 

6. Notwithstanding this motion to seal, the United States requests authorization to 
provide copies as necessary to conduct defendant’s initial appearance. 

WHEREFORE, the United States respectfully requests that the criminal complaint and all 
related filings, including the docket in this matter and this Motion to Seal and proposed Order, be 
sealed until further Order of the Court. 

Date: July 28, 2017 

Respectfully submitted, 

Robert S. Mueller, III 
Special Counsel 

By: /s/ _ 

Aaron S.J. Zelinsky 
Assistant Special Counsel 

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