Case 1:16-mc-00045-AJ Document 2 Filed 07/18/16 Page 1 of 2

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW HAMPSHIRE

)
IN RE APPLICATION OF THE )
UNITED STATES OF AMERICA FOR ) No.
AN ORDER AUTHORIZING THE )
INSTALLATION AND USE OF PEN ) Filed Under Seal
REGISTER AND TRAP AND )
TRACE DEVICES ON WHATSAPP, INC. )
ACCOUNT (978) 319-5705 )
)

MOTION TO SEAL APPLICATION FOR PEN REGISTER AND TRAP AND TRACE
DEVICES AND ALL RELATED DOCUMENTS, LEVEL II

The government respectfully requests that this entire matter including the enclosed

application for the installation of pen register and trap and trace devices, any orders issued by the

Court, this Motion to Seal, and all corresponding docket entries or other documents issued in the

above-captioned case be sealed at Level II until October 24, 2016.

In support, the government submits that this application relates to an ongoing criminal

investigation into a narcotics trafficking organization. Premature disclosure of certain details of

this investigation, the existence of this investigation or the fact that law enforcement authorities

are investigating the user of the account that is the subject of this application could obstruct or

seriously jeopardize the investigation. For example, if the targets of this narcotics investigation

became aware of this application or this investigation, this could cause them to flee, destroy

evidence, abandon this cell phone, commit acts of violence or otherwise obstruct the

investigation. Public disclosure of this request to install and use pen register and trap and trace

devices on a WhatsApp, Inc. Messenger account that is being used by a member of this drug

trafficking organization could undermine the ability of law enforcement officers to complete their
 Case 1:16-mc-00045-AJ Document 2 Filed 07/18/16 Page 2 of 2

investigation successfully.

Respectfully submitted,

Emily Gray Rice

United States Attorney

July 18, 2016 By: /s/ Georgiana L. Konesky

Georgiana L. Konesky
Assistant U.S. Attorney

Motion: ____ Granted ____ Denied

__________________________
Andrea K. Johnstone
United States Magistrate Judge

Dated: ______________