Case 2:18-cr-00422-DJH Document 1957 Filed 11/09/23 Page1of 2
`
`David M Morgan
`dba The Cochise County Record
`10 Quality Hill Rd
`PO Box 1218
`Bisbee, AZ 85603
`editor SVDR@gmail.com
`520-236-4051
`
`Proposed Intervenor
`
`
` NOV 0 92023
`
`CLERKU §DISTRICT
`DISTRICT OF ARIZONS
`
`
`
`
`eeDEPUTY
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF ARIZONA
`
`United States of America,
`Plaintiff
`
`V.
`
`MichaelLacey,et a/
`Defendants.
`
`CR-18-422-PHX-DJH
`
`_
`
`MOTION TO INTERVENE
`IN ORDER TO OBJECT
`TO GOVERNMENT'S
`MOTION FOR
`PROTECTIVE ORDER
`
`The First Amendment and commonlawprotect the public’s right of accessto judicial
`proceedings and court records. That right ensuresthat “the public [may] participate in
`and serve as a check uponthe judicial process—an essential componentin our
`structure of self-government.” Globe NewspaperCo. v. Superior Court, 457 U.S. 596,
`606 (1982).
`
`Promoting public scrutiny of the judicial process is especially important in caseslike
`this one, which involvesofficial allegations of serious crimes by owners and
`employees of a very successful online platform for user-generated advertising, and
`unofficial allegations that the government’s motivations for prosecution include
`personal andpolitical revenge.
`
`The proposedIntervenor is an independentjournalist and publisher focused on police-
`judicial-political systems in Arizona with special emphasis on First Amendment matters
`including access to court documents and otherpublic records.
`
`
`
`Case 2:18-cr-00422-DJH Document 1957 Filed 11/09/23 Page 2 of 2
`
`Morgan is a 2023 recipient of the Order of the Silver Key Society award by the Arizona
`chapter of the Society of Professional Journalists “for 25-plus years of notable
`journalism”.
`
`The public has a significant interest in monitoring and understanding any proceedings
`related to the government's efforts to interfere with the publishing of advertisements
`and/or prosecute the alleged crimes of a publisher.
`
`For the foregoing reasons, Morgan respectfully asks that the Court grant this motion to
`intervene and allow him time to retain counsel and prepare arguments objecting to the
`government's motion for protective order and supporting public accessto all exhibits
`which were the subject of argument, discussion or stipulation during all case
`proceedings.
`
`
`submitted,
`
`
`Dated November 9, 2023 /s/ DavidMMorgan
`
`
`
`David M Morgan
`Proposed Intervenor
`
`CERTIFICATE OF SERVICE
`
`| hereby certify that on November9, 2023, | filed the foregoing brief with the Clerk of
`the U.S. District Court for the District of Arizona in person.
`
`Participants in the case are registered CM/ECF users, and service will be
`
`accomplished by the CM/ECF system(Ce—
`
`
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