Jared Motion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF INDIANA

INDIANAPOLIS DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v. JARED FOGLE,

Defendant.

)))))))))

No. 15-CR-159 Judge Tanya Walton Pratt

MOTION TO MAINTAIN UNOPPOSED MOTION TO MODIFY CONDITIONS

OF RELEASE UNDER SEAL

Defendant, JARED FOGLE, by and through his attorneys, JEREMY MARGOLIS and

ANDREW DEVOOGHT, respectfully moves this Court to maintain under seal his unopposed

motion to modify conditions of release.

1. Today, September 17, 2015, Mr. Fogle filed an unopposed motion to modify

conditions of release under seal.

2. In his unopposed motion, Mr. Fogle respectfully requested permission from this

Court to travel outside of the Southern District of Indiana to undergo medical evaluation.

3. In his unopposed motion, Mr. Fogle provided this Court with the same

information and details regarding the requested medical evaluation that he has provided to the

United States Attorney’s Office and the United States Probation Office—neither of whom

oppose Mr. Fogle’s underlying motion.

4. Mr. Fogle’s case has attracted significant and sustained attention both from media

sources covering the case as well as individuals reaching out to Mr. Fogle’s attorneys and others

to express their views on Mr. Fogle’s case.

Case 1:15-cr-00159-TWP-MJD Document 26 Filed 09/17/15 of 3 PageID #: 84

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5. Given this substantial and sustained attention, Mr. Fogle respectfully submits that

the details of the medical evaluation he is seeking to undergo, including the location of the

medical facility and the timing of the requested medical evaluation, should remain under seal.

6. Permitting these details of Mr. Fogle’s request to remain under seal will not

simply ensure Mr. Fogle’s privacy and safety. It will also ensure the privacy and safety of the

personnel and other patients of the facility Mr. Fogle seeks to visit to obtain the requested

medical evaluation.

WHEREFORE, defendant JARED FOGLE respectfully asks that this Court to maintain

under seal his unopposed motion to modify conditions of release under seal.

Dated: September 17, 2015 By: /s/ Andrew DeVooght Jeremy Margolis Andrew DeVooght LOEB & LOEB LLP 321 N. Clark Street, Suite 2300 Chicago, IL 60647 Telephone: 312.464.3100 Facsimile: 312.464.3111 Attorneys for Defendant


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CERTIFICATE OF SERVICE

The undersigned certifies that all counsel of record who are deemed to have

consented to electronic service are being served with a copy of this document via

the Court’s CM/ECF system on this 17th day of September.

September 17, 2015 By: /s/ Andrew DeVooght Andrew DeVooght


IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF INDIANA

INDIANAPOLIS DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v. JARED FOGLE,

Defendant.

)))))))))

No. 15-CR-159 Judge Tanya Walton Pratt

[PROPOSED] ORDER GRANTING MOTION TO MAINTAIN UNDER SEAL

DEFENDANT’S UNOPPOSED MOTION TO MODIFY CONDITIONS O F RELEASE

This matter having come before the Court on defendant JARED FOGLE’s motion to maintain

under seal his motion to modify conditions of release.

And the Court, being duly advised, hereby GRANTS the motion and ORDERS that the

defendant’s motion to modify conditions of release be maintained under seal.

Dated: ______________________ ________________________________________ JUDGE TANYA WALTON PRATT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA Distribution: Service will be made electronically on all ECF-registered counsel of record via email generated by the court’s ECF system.

Case 1:15-cr-00159-TWP-MJD Document 26-1 Filed 09/17/15 Page 1 of 1 PageID #: 87

Jared Motion

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