UNITED STATES OF AMERICA,                       Plaintiff,                   v. MICHAEL BEKER, a.k.a. Mikhail Lvovich, a.k.a. Mendel Beker,      ARIE PRILIK and NEWCON INTERNATIONAL LTD.                   Defendants.

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PJH No. 07-CR-0765 Filed Under Seal: 12/04/2007 Seal Lifted: 04/15/2008 UNITED STATES' MOTION TO SEAL INDICTMENT AND ARREST WARRANT DOCUMENTS AND [PROPOSED] ORDER

The government hereby moves the Court for an order sealing this motion, the Indictment, the arrest warrant documents, and the sealing order until further order of the Court. The government requests that the order permit disclosure only to government counsel identified on this motion, law enforcement officials assisting in the investigation, and judicial officers, when necessary to perform their official duties. The defendants reside in Canada. The government believes that disclosure of the existence of the Indictment and arrest warrant, or the information contained in those documents, may jeopardize the progress of an ongoing criminal investigation, in that disclosure might assist the defendants avoid this jurisdiction.

DATED: December 4, 2007

Respectfully submitted,

_______________/s/________________ JEANE HAMILTON Attorney, Antitrust Division U.S. Department of Justice 450 Golden Gate Avenue Box 36046, Room 10-0101 San Francisco, CA 94102 Telephone: (415) 436-6660