UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

-----------------------------------------------------X UNITED STATES OF AMERICA : -v- : CASE No: 13cr10238DPW AZAMAT TAZHAYAKOV : : Defendant. -----------------------------------------------------X

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.

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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 June 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 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. 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.

Attorney for the Defendant Azamat Tazhayakov

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