Public First moved to unseal the Government’s motion for downward departure in sentencing for Defendant Kaulana Freitas and Defendant Freitas’s sentencing memorandum in United States v. Michael J. Miske, Jr., et al., No. 19-CR-99 DKW-KJM.

On March 9, 2022, Freitas pleaded guilty to a racketeering conspiracy and to using a chemical weapon. He did so in his capacity as an associate of Miske’s criminal enterprise. Under his plea agreement, Freitas agreed to cooperate with the Government. The Government, in turn, agreed that it “might make a motion for downward departure under 18 U.S.C. § 3553(e), Guidelines § 5K1.1, or Fed. R. Crim. P. 35(b).”  In advance of sentencing, the Government and Freitas filed documents under seal without first obtaining permission of the court.

The motion will be heard by the Honorable Derrick K. Watson.

• Motion to Unseal (4/3/26)