IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
September 3, 2009
UNITED STATES OF AMERICA, PLAINTIFF,
MARK ANTHONY CORRENTI, DEFENDANT.
The opinion of the court was delivered by: Hon. Gregory G. Hollows United States Magistrate Judge
STIPULATION AND PROTECTIVE ORDER REGULATING DISCOVERY
Pursuant to Fed. R. Crim. P. 16(d), the undersigned parties in United States v. Mark Anthony Correnti, stipulate and agree, and respectfully request that the Court order that:
1. The United States shall provide defense counsel with access to additional discovery in this case. This material consists of a Risk Management Report prepared by Placer County in connection with a claim filed by the defendant in what the government believes to be an unrelated civil matter (hereinafter "Protected Material"). Disclosure of the Protected Material may better facilitate the defendant's preparation for trial and/or his decision to resolve his case.
2. The Protected Material is now and will forever remain the property of Placer County, California. The Protected Material is being provided to the defendant only for purposes of representation in this case. The parties agree that the Protected Material is the work-product of Placer County and that Placer County is not waiving any privilege, or right to assert any privilege, over the Protected Material. Upon conclusion of the parties' examination of the Protected Material, the Protected Material will be returned to Placer County and any copies will be destroyed.
3. Counsel for the defendant shall not make any paper or electronic copy of any Protected Material.
4. Counsel for the defendant shall not reveal the contents of the Protected Material to any person other than the defendant, 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 information about the Protected Material from counsel shall be bound by the same obligations as counsel.
6. Counsel shall maintain a list of persons to whom information about 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.
7. To the extent that disclosure of the Protected Material is required under the Federal Rules of Discovery, Brady, Giglio, or the Jencks Act, such disclosure will be made in accordance with the rules of discovery.
Date: September 2, 2009
LAWRENCE G. BROWN United States Attorney
KYLE REARDON Assistant U.S. Attorney
Date: September 2, 2009
Kyle Reardon for
MATTHEW C. BOCKMON Counsel for the Defendant
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