ApolloMedia Motion to Augment Record and Strike Mis-statements
IN THE UNITED STATES COURT OF
UNITED STATES OF AMERICA,
SEALED APPELLANT 1,
Appeal from the United States District Court
for the Southern District of Texas, Houston Division
Magistrate's No. H-99-607-M
FILED UNDER SEAL
MOTION OF SEALED APPELLANT 1 TO AUGMENT RECORD AND STRIKE MISSTATEMENTS IN APPELLEE'S RESPONSE BRIEF
ApolloMedia Corporation files this Motion To Augment Record And Strike Misstatements In Appellee's Response Brief.
ApolloMedia moves to augment the Record in this matter by including therein the November 2, 1999 letter of Assistant U.S. Attorney, J. Richard Berry, attached hereto as Exhibit A.
Consideration of this letter will help to clarify the record by correcting misstatements that the Government has made in its Response. The Government erroneously states that it made an offer to ApolloMedia's attorneys to allow ApolloMedia to publish a redacted version of the Magistrate's Order in the proceedings before the District Court. Assistant U.S. Attorney Berry's letter, written after the Government filed its Opposition to ApolloMedia's Motion To Stay And To Unseal The Record before the District Court, contradicts these statements and demonstrates that the Government made no such offer.
Accordingly, ApolloMedia moves that the Court strike the first three full sentences on page 7 and footnote 3 of the Government's Response brief.
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