UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS

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UNITED STATES OF AMERICA :

-v- : CASE No: 13-cr-10238-DPW

AZAMAT TAZHAYAKOV :

:
Defendant.
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MOTION TO SEAL DEFENDANT AZAMAT TAZHAYAKOVS
MOTIONS IN LIMINE

NOW COMES the Defendant, Azamat Tazhayakov, who, by and through undersigned
counsel, respectfully moves this Honorable Court, to place his Motions in Limine under seal.
As grounds for this Motion, the Defendant states as follows:
1. The Motions in Limine includes references to official Federal Bureau of Investigation
reports that should not be subject to public disclosure at this time.
2. The Motions in Limine include references to evidence that we believe is irrelevant and
prejudicial to Mr. Tazhayakov, and should be precluded from his trial. Given the media attention to
this case, if Mr. Tazhayakovs Motions in Limine are publically filed, such irrelevant and
prejudicial evidence will be made public and likely result in prejudice to the defendant.
3. The defendant has provided an electronic copy of the Motions in Limine to the
Government and has mailed a copy to the Court to be placed under seal.

Case 1:13-cr-10238-DPW Document 242 Filed 06/10/14 Page 1 of 2
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WHEREFORE, the Defendant respectfully moves this Court to place his Motions in Limine
under seal and keep said document impounded until further order of the Court.

Dated: New York, New York
J une 9, 2014
Respectfully submitted,

/s/ Nicholas M. Wooldridge______
Nicholas M. Wooldridge, Esq.
Bukh & Associates, PLLC
1123 Avenue Z
Brooklyn, New York 11235
(718) 376-6466




CERTIFICATE OF SERVICE
I hereby certify that on this 9th day of J une, 2014, I served a copy of the foregoing MOTION TO
FILE DEFENDANT AZAMAT TAZHAYAKOVS MOTIONS IN LIMINE UNDER SEAL on
Assistant United States Attorneys J ohn A. Capin and B. Stephanie Siegmann by electronic mail.

/s/ Nicholas M. Wooldridge____
Nicholas M. Wooldridge, Esq.
Attorney for the Defendant Azamat
Tazhayakov

Case 1:13-cr-10238-DPW Document 242 Filed 06/10/14 Page 2 of 2
CERTIFICATE OF SERVICE


I hereby certify that on this 9th day of June, 2014, I served a copy of the foregoing MOTION
TO FILE DEFENDANT AZAMAT TAZHAYAKOVS MOTIONS IN LIMINE UNDER
SEAL on Assistant United States Attorneys John A. Capin and B. Stephanie Siegmann by
electronic mail.


/s/ Nicholas M. Wooldridge____
Nicholas M. Wooldridge, Esq.
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