STIPULATION AND PROTECTIVE ORDER BETWEEN THE UNITED STATES AND DEFENDANTS JAMES LEE LANKFORD AND JON JON VANCE MCDADE
WHEREAS, the discovery in this case is voluminous and contains a large amount of personal information including, but not limited to social security numbers, dates of birth, email addresses, telephone numbers, residential addresses, and bank account numbers ("Protected Information"); and
WHEREAS, the parties desire to avoid both the necessity of large scale redactions and the unauthorized disclosure or dissemination of this information to anyone not a party to the court proceedings in this matter;
The parties agree that entry of a stipulated protective order is appropriate.
THEREFORE, defendant JAMES LEE LANKFORD, by and through his counsel of record Victor Chavez ("Lankford Defense Counsel"), defendant JON JON VANCE MCDADE, by and through his counsel of record Eric Fogderude ("McDade Defense Counsel"), and plaintiff United States of America, by and through its 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 (hereafter, collectively known as "the discovery") provided to or made available to Lankford Defense Counsel and McDade Defense Counsel, (hereafter collectively known as "Defense Counsel"), by the United States in this case.
3. By signing this Stipulation and Protective Order, Defense Counsel agrees not to share any documents that contain Protected Information with anyone other than case co-counsel (if any) and designated defense investigators and support staff. Defense Counsel may permit the defendants to view unredacted documents in the presence of his attorney, defense investigators and support staff. The parties agree that Defense Counsel, defense investigators and support staff shall not allow the defendants to copy Protected Information contained in the discovery. The parties agree that Defense Counsel, defense investigators, and support staff may provide the defendants with copies of documents from which Protected Information has been redacted.
4. The discovery and information therein may be used only 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. At the conclusion of the case, Defense Counsel will return the discovery to the Government or will certify that it has been shredded.
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. Defense Counsel shall be responsible for advising the defendants, employees, and other members of the defense teams, and defense witnesses of the contents of this Stipulation/Order.
7. In the event that the defendant(s) substitutes counsel, undersigned Defense Counsel agrees to withhold discovery from new counsel unless and until substituted counsel agrees also to be bound by this Order.
BENJAMIN B. WAGNER United States Attorney MICHELE THIELHORN ...