The opinion of the court was delivered by: Morrison C. England, Jr. United States District Judge
STIPULATION AND PROTECTIVE ORDER BETWEEN UNITED STATES AND NAMED DEFENDANTS
WHEREAS, the parties desire to prevent the unauthorized disclosure or dissemination of certain sensitive but unclassified discovery materials to anyone not a party to the court proceedings in this matter; and
WHEREAS, the parties agree that entry of a stipulated protective order is appropriate;
Defendants Ramanathan Prakash, Shushanik Martirosyan, Nazaret Salmanyan, Alexander Popov, Liw Jiaw Saechao and Lana Le Chabrier, and Plaintiff, the United States of America, by and through their counsel of record, hereby agree and stipulate as follows:
1. This Court may enter protective orders pursuant to Rule 16(d) of the Federal Rules of Criminal Procedure, and its general supervisory authority.
2. This Order pertains to all discovery provided to or made available to Defense Counsel as part of discovery in this case (hereafter, collectively known as "the discovery").
3. Defense Counsel shall not disclose any of the discovery to any person other than their respective defendant/client, or attorneys, law clerks, paralegals, secretaries, experts, and investigators, involved in the representation of his/her defendant/client.
4. The discovery and information therein may only be used in connection with the litigation of this case and for no other purpose. The discovery is now and will forever remain the property of the United States Government. Defense Counsel will return the discovery to the Government or certify that it has been shredded at the conclusion of the case.
5. Defense Counsel will store the discovery in a secure place and will use reasonable care to ensure that it is not disclosed to third persons in violation of this agreement.
6. If Defense Counsel release custody of any of the discovery, or authorized copies thereof, to any person described in paragraph (3), Defense Counsel shall provide such recipients with copies of this Order and advise that person that the discovery is the property of the Unites States Government, that the discovery and information therein may only be used in connection with the litigation of this case and for no other purpose, and that an unauthorized use of the discovery may constitute a violation of law and/or contempt of court.
7. Defense Counsel shall be responsible for advising his or her respective defendant, employees, and other members of the defense team, and defense witnesses of the contents of this Stipulation/Order.