Federal Court Filing: Motion To Seal And To Delay Disclosure, 06 (EFTA00221125)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 06- -LRJ IN RE: RECORDS OF THE ELECTRONIC COMMUNICATIONS SERVICE KNOWN AS CINGULAR WIRELESS MOTION TO SEAL AND TO DELAY DISCLOSURE The United States of America, by and through the undersigned Assistant United States Attorney, hereby moves to seal its Motion for Order of Disclosure under 18 U.S.C. § 2703 and to delay disclosure to the target of the Motion and Order for the following reasons: I. Delay of notification of disclosure of the Motion and the response thereto is permitted for 90 days pursuant to 18 U.S.C. § 2705(a), where such disclosure may result in (1) endangering the life or physical safety of an individual, (2) flight from prosecution, (3) destruction of or tampering with evidence; (4) intimidation of potential witnesses; or (5) otherwise seriously jeopardize an investigation or unduly delay a trial. 18 U.S.C. § 2705(b). 2. As set forth in the Motion, there is probable cause to believe that