P LAINTIFF ’ S M OTION TO F ILE U NDER S EAL P AGE 1 OF 2 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS FORTH WORTH DIVISION JOHN ANTHONY CASTRO, Plaintiff, VS. THE UNITED STATES OF AMERICA, Defendant. § § § § § § § § § § Civil Action No.: 4-22CV-0016-O PLAINTIFF'S MOTION TO SEAL COMES NOW, Plaintiff, John Anthony Castro, submits his motion to seal the above-titled civil case per LR 79.3(b)) and states in support thereof: 1. This case involves the unlawful disclosure by an IRS Agent of Plaintiff’s alleged tax criminal investigation and grand jury indictment to third parties. 2. To date, the U.S. Government has not charged Plaintiff with any criminal conduct. 3. Plaintiff had no other option but to bring this suit to prevent the IRS from further contacting third parties to disclose confidential tax information, as a civil suit is the only means to notify the IRS of one of their agent’s misconduct and prevent further misconduct. 4. By bringing this civil suit, Plaintiff’s confidential tax information is now available for public viewing which will cause irreparable harm Plaintiff’s professional reputation. 5. Further, Plaintiff is primary presidential candidate for the Republican Party (P40007320) for the 2024 Presidential Election. The alleged criminal investigation has no merits as the U.S. Government never filed any charges against the Plaintiff, however, the disclosure of this case can harm Plaintiff’s political career. Case 4:22-cv-00016-O-BP Document 18 Filed 05/02/22 Page 1 of 2 PageID 154 P LAINTIFF ’ S M OTION TO F ILE U NDER S EAL P AGE 2 OF 2 6. The probable adverse effect on Plaintiff clearly outweighs the presumption of openness. 7. Defendant informed Plaintiff that Defendant opposes the granting of this motion. WHEREOF, Plaintiff requests that this civil claim will be placed under seal from the public. May 2, 2022 Respectfully submitted By:__ ____ _________________ JOHN ANTHONY CASTRO 12 Park Place Mansfield, TX 76063 Tel. (202) 792- 6600 J.Castro@CastroandCo.com PLAINTIFF PRO SE Case 4:22-cv-00016-O-BP Document 18 Filed 05/02/22 Page 2 of 2 PageID 155