UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF TEXAS 

EL PASO DIVISION 

UNITED STATES OF AMERICA, 

v 

PATRICK WOOD CRUSIUS, 

Defendant. 

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No. 3:20-CR-00389 

(The Honorable David C. Guaderrama) 

MOTION FOR LEAVE TO FILE 

MOTION TO INTERVENE AND UNSEAL JUDICIAL RECORDS 

El Paso Matters, a nonprofit media organization focused on in-depth and investigative 

reporting about the El Paso and Paso del Norte region, hereby moves for leave to intervene in the 

above-captioned case for the limited purpose of seeking an order unsealing judicial records in this 

matter. This Motion is made on the grounds that: 

1. As a news organization, El Paso Matters may intervene for the limited purpose of 

seeking an order unsealing court documents and opposing court closure. 

2. On November 2, 2023, the United States (the "Government" or "prosecution") filed 

a motion to unseal certain sealed records in the above-captioned case. El Paso Matters agrees with 

the Government's argument that those records should be unsealed and, further, seeks to unseal the 

remaining sealed records in this matter, including docket entries currently missing from the public 

docket. 

3. El Paso Matters has a First Amendment right to access judicial records filed with 

the Court in this matter, and said constitutional right is not overcome. 

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4. El Paso Matters has a common law right to access judicial records filed with the 

Court in this matter, and said common law right is not overcome. 

5. To the extent compelling interests overcome El Paso Matters' constitutional and 

common law rights of access as to any portion of the sealed records in this matter, any sealing or 

closure must be n'o broader than necessary to serve those interests and must be supported by 

specific, on-the-record factual findings. 

El Paso Matters seeks leave to file its Motion to Intervene and to Unseal Judicial Records, 

attached hereto as,Exhibit A (the "Motion"). The Motion seeks to unseal all pleadings, records, 

and files in the above-captioned case, all matters of which the Court shall take judicial notice, and 

on such argument a may be presented at a hearing on its Motion. 

CONCLUSION AND PRAYER 

El Paso Matters respectfully requests that the Court grant its motion to intervene and permit 

its Motion to Intervene and Unseal to be filed in this proceeding. El Paso Matters further requests 

an order unsealing all pleadings, records and files in this matter. 

Dated: November 21, 2023 Respectfully submitted, 

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/s/Arnanda N. Crouch 

Amanda N. Crouch 

State Bar No. 24077401 

JACKSON WALKER LLP 

1900 Broadway, Suite 1200 

San Antonio, TX 78215 

acrouchjw.com 

/s/ Katie Townsend 

Katie Townsend* 

REPORTERS COMMITTEE FOR 

FREEDOM OF THE PRESS 

Case 3:20-cr-00389-DCG Document 311 Filed 11/21/23 Page 2 of 5
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1156 15th St. NW, Suite 1020 

Washington, D.C. 20005 

Phone: 202.795.9300 

Facsimile: 202.795.9310 

ktownsend@rcfp.org 

Counsel/or Proposed Intervenor 

El Paso Matters 

* Pro hac vice application pending 

Case 3:20-cr-00389-DCG Document 311 Filed 11/21/23 Page 3 of 5
CERTIFICATE OF CONFERENCE 

I certify that I contacted Ian Hanna, counsel for the United States in this matter, and Joe 

Spencer, counsel or Defendant, via e-mail on November 16, 2023, to ascertain their clients' 

position on the relief sought by this Motion. The United States takes no position on this Motion 

and the defense opposes it. 

/s/Amanda N. Crouch 

Amanda N. Crouch 

counsel for El Paso Matters 

Case 3:20-cr-00389-DCG Document 311 Filed 11/21/23 Page 4 of 5
CERTIFICATE OF SERVICE 

I hereby certify that a copy of the foregoing was electronically filed on November 21, 2023. 

Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing 

system. Parties ma' access this filing through the Court's system. 

/s/Amanda N. Crouch 

Amanda N. Crouch 

Counsel for El Paso Matters 

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