IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
August 17, 2009
UNITED STATES OF AMERICA, PLAINTIFF,
MICHAEL MCCORMICK, DEFENDANT.
CORRECTED AND SIGNED STIPULATION AND PROTECTIVE ORDER REGULATING DISCOVERY
Pursuant to Fed. R. Crim. P. 16(d), the undersigned parties in United States v. McCormick, stipulate and agree, and respectfully request that the Court order that:
1. The United States shall turn over additional discovery in this case, namely electronic evidence contained on a computer hard drive ("The Protected Material"). Disclosure of The Protected Materials may better facilitate the Defendant's preparation for sentencing.
2. The Protected Material is now and will forever remain the property of the United States. The Protected Material is entrusted to counsel for the Defendant only for purposes of representation in this case.
3. Counsel for the Defendant shall not make any paper or electronic copy of any Protected Material.
4. Counsel for the Defendant shall not give the Protected Material to any person other than counsel's staff or investigator. The terms "staff" and "investigator" shall not be construed to describe any Defendant or other person not either regularly employed by counsel or a licensed investigator hired in this case.
5. Any person receiving the Protected Material from counsel for the Defendant shall be bound by the same obligations as counsel and, further may not give the Protected Material to anyone (except that the Protected Material shall be returned to counsel).
5. Counsel shall maintain a list of persons to whom any Protected Material has been given. Such persons shall be shown a copy of this Stipulation and Order and shall sign a copy of the Stipulation and Order and note that they understand its terms and agree to them.
6. The Defendant in this case may review the Protected Materials and be aware of their contents, but shall not be given control of the Protected Materials or any copies thereof.
7. Within twenty days of sentencing, that Defendant's counsel shall destroy the Protected Material and so certify to the attorney for the government.
DATE: August 17, 2009
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