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

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 Attorneys Office and the United States Probation Officeneither of whom
oppose Mr. Fogles underlying motion.
4.

Mr. Fogles case has attracted significant and sustained attention both from media

sources covering the case as well as individuals reaching out to Mr. Fogles attorneys and others
to express their views on Mr. Fogles case.

Case 1:15-cr-00159-TWP-MJD Document 26 Filed 09/17/15 Page 2 of 3 PageID #: 85

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. Fogles request to remain under seal will not

simply ensure Mr. Fogles 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

Case 1:15-cr-00159-TWP-MJD Document 26 Filed 09/17/15 Page 3 of 3 PageID #: 86

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 Courts CM/ECF system on this 17th day of September.

September 17, 2015

By: /s/ Andrew DeVooght

Andrew DeVooght

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

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

DEFENDANTS UNOPPOSED MOTION TO MODIFY CONDITIONS OF RELEASE
This matter having come before the Court on defendant JARED FOGLEs 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
defendants 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 courts ECF system.