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IN THE UNITED STATES DISTRICT COURT FOR THE 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO: 20-22829-CR-LFL 

IN THE MATTER OF THE 

EXTRADITION OF 

CESAR HORACIO DUARTE JAQUEZ

 / 

CÉSAR DUARTE’S MOTION TO SEAL EXHIBITS

 Respondent, César Horacio Duarte Jáquez (“Mr. Duarte”), respectfully moves to file under 

seal Exhibits 1, 3, and 4 to his response to the Government’s Memorandum in Support of 

Extradition (ECF No. 23, the “Extradition Memorandum”). Mr. Duarte requests that the 

documents remain under seal for one year, and that the Court, before unsealing them, hear from 

the parties on whether they should remain sealed. In support of this motion, Mr. Duarte states as 

follows: 

 Exhibits 1, 3, and 4 are declarations of witnesses whose testimony implicates the current 

governor of Chihuahua, Javier Corral Jurado, and his administration’s political persecution of Mr. 

Corral’s political rivals, including the Corral administration’s efforts to coerce witness testimony 

implicating Mr. Corral’s political rivals in criminal conduct. As a result of their declarations, the 

witnesses may face significant reprisal from the Mexican government and the State of Chihuahua 

should their identities be publicly revealed. The Corral administration has a well-documented 

history of persecuting perceived allies of Mr. Duarte, from raiding the property of Mr. Duarte’s 

neighbor and physically assaulting him, see ECF No. 14, Exhibit 13 at 13-14, to threatening former 

members of Mr. Duarte’s administration with fabricated criminal charges if they did not testify 

against him, see ECF No. 14, Exhibit 14 at 7-8. To the extent the Corral administration perceives 

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the witnesses’ declarations as constituting an allegiance with Mr. Duarte, they risk a similar fate. 

Mr. Duarte thus seeks to have these declarations placed under seal. 

 Undersigned counsel conferred with counsel for the government, Jason Wu, on January 30, 

2020. The government opposes this motion to seal. 

 WHEREFORE, Mr. Duarte respectfully requests that the Court enter an order granting this 

motion to seal and permit him to file under seal the documents (exhibits) described in this motion. 

A proposed order is attached. 

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Dated: December 30, 2020. Respectfully submitted, 

BELL ROSQUETE REYES ESTEBAN, PLLC 

999 Ponce De Leon Blvd. 

Suite 1120 - Penthouse 

Coral Gables, Florida 33134 

Telephone: (305) 570-1610 

Facsimile: (305) 570-1599 

By: /S/ Henry P. Bell 

HENRY P. BELL 

Florida Bar No. 0090689 

hbell@brresq.com 

-andBy: /S/ Armando Rosquete 

ARMANDO ROSQUETE 

Florida Bar No. 648434 

arosquete@brresq.com 

QUINN EMANUEL URQUHART & 

SULLIVAN, LLP 

1300 I Street NW, Suite 900 

Washington, DC 20005 

Telephone: (202) 583-8000 

Facsimile: (202) 583-8100 

By: /S/ Juan Morillo 

JUAN MORILLO 

Florida Bar No. 135933 

juanmorillo@quinnemanuel.com 

-andGIANNA PUCCINELLI 

Admitted pro hac vice 

giannapuccinelli@quinnemanuel.com 

Case 1:20-mc-22829-UNA Document 58 Entered on FLSD Docket 12/30/2020 Page 3 of 4
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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on December 30, 2020 a true and correct copy of the 

foregoing has been furnished electronically via ECF to all counsel of record. 

By: /S/ Juan Morillo 

 JUAN MORILLO 

Case 1:20-mc-22829-UNA Document 58 Entered on FLSD Docket 12/30/2020 Page 4 of 4