USA v. Winner

MOTION to Intervene for the Limited Purpose of Seeking Access to Certain Sealed Court Records Related to this Action

S.D. Ga.March 7, 2019

U.S. DISTRICT COUR" AUGUSTA [TV IN THE UNITED STATES DISTRICT COURT 2019 MiSf? 7 PM » OQ SOUTHERN DISTRICT OF GEORGIA ' rn AUGUSTA DIVISION UNITED STATES V. REALITY WINNER CLERK.XJA> SO. Ij!3 f. 0, GA. Case No. l:17-cr-34 (JRH) (BKIE) REPORTERS COMMITTEE FOR FREEDOM OF THE PRESS'S MOTION TO INTERVENE FOR THE LIMITED PURPOSE OF SEEKING ACCESS TO CERTAIN SEALED COURT RECORDS RELATED TO THIS ACTION The Reporters Committee for Freedom of the Press hereby moves this court to permit it to intervene for the limited purpose of seeking access to certain sealed court records related to this action, specifically, any and all applications and supporting documents, including affidavits, concerning the completed "leak" investigation and now-concluded criminal prosecution of Reality Winner seeking any of the following; any court orders granting or denying any of the following; and any other court records related to the following, such as returns, motions to seal, and docket sheets: • any search warrant, regardless of whether the warrant was issued or executed, including warrants under the Stored Communications Act ("SCA"), see 18 U.S.C. §§ 2701-2712; • authorization for the use of any pen register or trap and trace device pursuant to 18 U.S.C. §§ 3121-3127, regardless of whether such authorization was granted or a pen register or trap and trace device was used; and • any order pursuant to 18 U.S.C. § 2703(d) of the SCA, regardless of whether or not the order was issued or executed. A supporting memorandum of law is attached. Case 1:17-cr-00034-JRH-BKE Document 333 Filed 03/07/19 Page 1 of 3 Dated: , 2019 Respectfully submitted, /s/David E. Hudson David E. Hudson Ga. Bar No. 374450 Hull Barrett SunTrust Bank Building, 801 Broad Street Seventh Floor Augusta, GA 30901 Tel: (706) 722-4481 Peter C. Canfield Ga. Bar No. 107748 Meredith C. Kincaid Ga. Bar No. 148549 Jones Day 1420 Peachtree Street, NE, Suite 800 Atlanta, GA 30309 Tel: (404) 521-3939 Counsel of Recordfor Applicant the Reporters Committee for Freedom of the Press Bruce D. Brown* Katie Townsend* Linda Moon* The Reporters Committee for Freedom of the Press 115615th St. NW, Suite 1020 Washington, DC 20005 Tel: (202) 795-9300 *0/ Counsel for Applicant the Reporters Committee for Freedom of the Press Case 1:17-cr-00034-JRH-BKE Document 333 Filed 03/07/19 Page 2 of 3 CERTIFICATE OF SERVICE I hereby certify that on , 2019,1 electronically filed the foregoing with the Clerk of the Court using the ECF system, which sent notification of such filing to counsel of record for all parties. /s/ David E. Hudson David E. Hudson Case 1:17-cr-00034-JRH-BKE Document 333 Filed 03/07/19 Page 3 of 3