Guo Wengui / Miles Guo — criminal case · MOTION · ECF #741

Defendants.

MOTION TO SEAL PERSONAL INFORMATION OR PROCEED PSEUDONYMOUSLY

TO THE HONORABLE ANALISA TORRES, UNITED STATES DISTRICT JUDGE:

I, (Petitioner) appearing pro se, respectfully move this Court to seal my personal information (e.g., name, address, phone number, email, financial details, HID: redacted) in all court filings related to my Third-Party Petition or, in the alternative, permit me to proceed pseudonymously as “Petitioner,” pursuant to Federal Rule of Civil Procedure 5.2, Local Rule 5.3, and the Court’s inherent authority. 1. Basis for Motion: Public disclosure of my personal and financial information risks personal safety, financial harm, harassment, or reputational damage due to the politically sensitive nature of this case (United States v. Ho Wan Kwok, Case No. 1:23-cr-00118-AT) and its association with politically sensitive matters involving the Himalaya Exchange, Alliance Farms, and bankruptcy proceedings (Case No. 22-50073, U.S. Bankruptcy Court, District of Connecticut). 2. Legal Support: Sealing or pseudonymity is supported by Doe v. Megless, 654 F.3d 404 (3d Cir. 2011) and Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185 (2d Cir. 2008), which allow privacy protection when public disclosure poses significant risks. 3. Request: I request that the Court seal my personal information in all filings, including the Third-Party Petition and Exhibits 1–30, or permit me to proceed pseudonymously. I have

submitted redacted versions of all documents for public filing and unredacted versions for sealed filing, as required.