IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

EL PASO DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v.

PATRICK WOOD CRUSIUS,

Defendant. 

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CAUSE NO.: EP-20-CR-00389-DCG

MOTION TO UNSEAL 

Comes now, the United States of America, by and through the United States Attorney for 

the Western District of Texas, and moves the Court for an order to unseal certain documents, and 

for a limited unsealing of certain other documents, in the above-captioned matter. In support 

thereof, the Government submits the following:

I. Background

On February 6, 2020, a federal grand jury sitting in the Western District of Texas, El Paso 

Division returned a ninety-count indictment in the above-captioned case charging Patrick Wood 

Crusius with twenty-two death-resulting hate crime offenses, twenty-three additional hate crime 

offenses involving an attempt to kill, and forty-five related firearm offenses. Twenty-two of these 

firearm offenses carry a potential death sentence. (ECF No. 1). On July 9, 2020, a federal grand 

jury sitting in the Western District of Texas, El Paso Division returned a superseding indictment 

in the above-captioned case to include in addition to the original counts the death of an additional 

victim. (ECF No. 82). These charges arise from an August 3, 2019, mass shooting at a Walmart 

located in El Paso, Texas.

Case 3:20-cr-00389-DCG Document 308 Filed 11/02/23 Page 1 of 6
As reflected in the Indictments, the shooting killed twenty-three people and injured several 

more. Given the time and location of the incident, there were hundreds of witnesses to the 

shooting. Hundreds of local, state, and federal law enforcement officers and first responders 

played a role in responding to the attack and its aftermath. Those entities amassed a tremendous 

amount of material. 

The investigation into the mass shooting on August 3, 2019, progressed on dual federal 

and state tracks since its inception. On September 12, 2019, and on June 25, 2020, a Grand Jury

for the 34th Judicial District sitting in El Paso County returned indictments charging Patrick Wood 

Crusius with capital murder of multiple persons for allegedly executing the August 3, 2019, mass 

shooting and announced that it would seek the death penalty. 

On February 14, 2020, this honorable court issued a Protective Order Governing Discovery 

(the “Protective order”) in the above-captioned case, (ECF No. 39); this order remains in place.

On February 8, 2023, Defendant Patrick Wood Crusius pleaded guilty pursuant to a 

written plea agreement (ECF No. 259) to all counts contained in the ninety-count superseding 

indictment (ECF No. 82). In that plea agreement, Defendant agreed and stipulated to pay 

restitution in an amount determined by the Court. 

On July 7, 2023, Defendant Patrick Wood Crusius was sentenced to serve ninety consecutive 

life sentences, five years of supervised release per count to be served concurrently, and a $9,000 special 

assessment. 

On October 5, 2023, Defendant Patrick Wood Crusius’ sentence was amended to include 

an order to pay restitution in the amount of $6,238,845.55 (ECF No. 302). 

The State case against Defendant Patrick Wood Crusius remains pending. 

Case 3:20-cr-00389-DCG Document 308 Filed 11/02/23 Page 2 of 6
II. Unsealing

During the course of the above referenced litigation, the Parties each sought leave of the 

Court to file sealed documents. The Government specifically moved the Court for permission to 

file the following ECF documents under seal: Attachments 1, 2, 3, and 4 to ECF No. 72; ECF

No. 73 and attachments 1, 2, 3, and 4; ECF No. 233; ECF No. 234; ECF No. 246; and ECF No. 

248. The Court granted the requested leave, and those documents were subsequently filed under 

seal. The Court subsequently issued sealed orders relevant to the above sealed documents; those 

sealed orders are found in ECF documents numbered 235, 247, and 249. 

As the federal criminal matter in the above referenced cause number has now been 

concluded, the United States sees no further reason to have ECF documents numbered 73, 233, 

234, 246, and 248 remain under seal. The Government is also of the opinion that the sealed court 

orders issued relevant to those documents – ECF documents numbered 235, 247, and 249 -

should additionally be unsealed.

The sealed attachments to ECF documents numbered 72 and 73 (attachments 1, 2, 3, & 4 

to both documents), however, contain material that the Government believes should remain 

under seal. That information consists of personal identifiable information related to victims in 

this case, information that remains subject to the Court’s Protective Order, and/or information 

that could materially impact the conduct of the pending state case. The Government will seek 

leave of court to attach to this filing redacted copies of attachments 1, 2, 3, and 4 to ECF 

documents numbered 72 and 73, and propose that those redacted versions be unsealed as 

substitutes for the originally filed documents. 

WHEREFORE, PREMISES CONSIDERED, the Government respectfully requests that 

ECF documents numbered 73, 233, 234, 246, and 248 be unsealed. The Government further 

Case 3:20-cr-00389-DCG Document 308 Filed 11/02/23 Page 3 of 6
requests that the corresponding court orders to these documents, ECF documents numbered 235, 

247, and 249, also be unsealed. Lastly, the Government requests that sealed attachments 1, 2, 3, 

and 4 to ECF documents numbered 72 and 73 be unsealed in a limited fashion consistent with 

the redactions proposed by the Government. 

Respectfully Submitted,

MARGARET LEACHMAN

ATTORNEY FOR THE UNITED STATES, 

ACTING UNDER AUTHORITY CONFERRED BY 28 U.S.C. § 515

___________________________________

IAN MARTINEZ HANNA

Assistant United States Attorney

Texas Bar # 24057885

700 East San Antonio, Suite 200

El Paso, Texas 79901 

___________________________________

GREGORY MCDONALD

Assistant United States Attorney

Texas Bar # 13547300

700 East San Antonio, Suite 200

El Paso, Texas 79901 

Case 3:20-cr-00389-DCG Document 308 Filed 11/02/23 Page 4 of 6
CERTIFICATE OF SERVICE

I hereby certify that on the 2nd day of November, 2023, a true and correct copy of the 

foregoing instrument was electronically filed with the Clerk of the Court using the CM/ECF 

System and the Government provided a copy to the following participants: 

Joseph Spencer and Felix Valenzuela 

Attorneys for Defendant 

__________//s//___________

Ian M. Hanna 

Assistant U.S. Attorney

Case 3:20-cr-00389-DCG Document 308 Filed 11/02/23 Page 5 of 6
IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

EL PASO DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v.

PATRICK WOOD CRUSIUS,

Defendant.

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CAUSE NO.: EP-20-CR-00389-DCG

ORDER 

On this date came on to be considered the Government's Motion to Unseal ECF 

Documents numbered 73, 233, 234, 235, 246, 247, 248, and 249, and for the limited unsealing of 

attachments 1, 2, 3, and 4 to ECF documents numbered 72 and 73, in the above numbered cause, 

and the Court having considered the same, is of the opinion that said Motion should be granted. 

IT IS THEREFORE ORDERED that the Motion to Unseal ECF Documents numbered 

73, 233, 234, 235, 246, 247, 248, and 249, and for the limited unsealing of attachments 1, 2, 3, 

and 4 to ECF documents numbered 72 and 73, in the above numbered cause be GRANTED. 

SIGNED and ENTERED this the ________ day of November, 2023. 

_______________________________

HONORABLE DAVID C. GUADERRAMA

SENIOR UNITED STATES DISTRICT JUDGE

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