USA v. HandMOTION for Leave to File Motion Under Seal as to Learned Jeremiah Hand.D. Mass.March 6, 2019UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS UNITED STATES OF AMERICA v. LEARNED JEREMIAH HAND, Defendant. Criminal No. 16-cr-10222-PBS MOTION FOR LEAVE TO FILE MOTION UNDER SEAL Defendant Learned Jeremiah Hand hereby moves for leave of court to file a Motion for Emergency Sentencing Relief (the “Relief Motion”) under seal. In support of this motion, Mr. Hand states that the Relief Motion should be filed under seal because it contains sensitive and highly personal medical information regarding the defendant. LEARNED JEREMIAH HAND By his attorneys, /s/ David J. Apfel David J. Apfel (BBO # 551139) GOODWIN PROCTER LLP 100 Northern Avenue Boston, MA 02210 Tel.: 617-570-1000 Fax: 617-523-1231 dapfel@goodwinlaw.com Dated: March 6, 2019 Case 1:16-cr-10222-PBS Document 88 Filed 03/06/19 Page 1 of 2 2 LOCAL RULE 7.1(a)(2) CERTIFICAITON I, David J. Apfel, Esq. certify that I have twice reached out to the government by email to obtain its assent to the above motion, or to otherwise resolve or narrow the issue presented by the above motion, but to date have not yet heard back from counsel for the government. /s/ David J. Apfel David J. Apfel, Esq. CERTIFICATE OF SERVICE I, David J. Apfel, Esq., certify that the foregoing Motion for Leave to File Motion Under Seal, which was filed through the ECF system on March 6, 2019, shall be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) and paper copies will be sent to those indicated as non-registered participants on March 6, 2019. /s/ David J. Apfel David J. Apfel, Esq. ACTIVE/98765592.1 Case 1:16-cr-10222-PBS Document 88 Filed 03/06/19 Page 2 of 2
