IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
August 4, 2008
UNITED STATES OF AMERICA, PLAINTIFF,
ROBERT MARTINSON, SHERYL HAYDEN, KATHLEEN DELAPP, MELISSA VILLEGAS, AND RICK VILLEGAS, DEFENDANTS.
The opinion of the court was delivered by: Edward J. Garcia U.S. District Judge
STIPULATION AND ROTECTIVE ORDER RE: DISSEMINATION OF DISCOVERY DOCUMENTS CONTAINING NAMES AND PERSONAL IDENTIFYING INFORMATION
IT IS HEREBY STIPULATED AND AGREED among the parties and their respective counsel, Russell L. Carlberg, Assistant U.S. Attorney, representing plaintiff United States of America, and Christopher H. Wing, attorney for defendant Robert Martinson, James R. Greiner, attorney for defendant Sheryl Hayden, William Portanova, attorney for defendant Kathleen Delapp, Bruce Locke, attorney for defendant Melissa Villegas, and Timothy Warriner, attorney for defendant Rick Villegas, that the documents provided as discovery in this case to defense counsel which contain names and personal identification information such as addresses, telephone numbers, social security numbers, and bank account numbers of individuals other than the defendants are subject to a Protective Order and that by signing this Stipulation and Protective Order counsel agrees not to share any such documents that contain personal identification information with anyone other than defense counsel and his/her designated defense investigators and support staff. Any pages of discovery that contain no personal identification information, or contain only victim names, but no additional personal identifying information, are not subject to this order.
Defense counsel may permit the defendants to view the documents in the presence of his or her attorney or defense investigators, so long as defense counsel and the defense investigators do not allow the defendant to copy the personal identification information contained in the discovery, and defense counsel and the defense investigators do not allow the defendant to retain copies of these records.
In the event that a defendant substitutes counsel, undersigned defense counsel each agree to withhold these documents from new counsel unless and until substituted counsel agrees also to be bound by this order.
DATE: July 28, 2008
IT IS SO ORDERED:
© 1992-2008 VersusLaw Inc.