The old document charged the parents with child abuse, The (Boulder) Daily Camera reported Tuesday.
Judge Robert Lowenbach had ordered the Boulder district attorney's office to "file any requested document under seal" Monday in response to a lawsuit filed by a reporter in September seeking access to the apparent indictment, the report said.
The document from 1999 was sent to the judge by Boulder District Attorney Stan Garrett.
The Reporters Committee for Freedom of Press joined Daily Camera reporter Charlie Brennan in his lawsuit, in which he sought access to what was believed to be an indictment charging Patsy and John Ramsey with child abuse resulting in JonBenet's death. Alex Hunter, the district attorney at the time, refused to sign the document and the Ramseys were cleared in 2008, two years after Patsy Ramsey's death from cancer.
No one has been convicted of killing JonBenet, who was found in 1996 in the basement of her family's home in Boulder.
Lowenbach will now review what is believed to be the indictment charging the parents to determine if it can be released to Brennan.