BENJAMIN B. WAGNER United States Attorney MATTHEW STEGMAN Assistant U.S. Attorney 501 I Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2700
STIPULATION AND PROTECTIVE ORDER RE: DISSEMINATION OF DISCOVERY DOCUMENTS CONTAINING NAMES AND PERSONAL IDENTIFYING INFORMATION
Pursuant to Fed. R. Crim. P. 16(d), the undersigned parties stipulate and agree, and respectfully request that the Court order that:
1. All discovery provided from the government from this date forward to the defense attorney shall be subject to this protective order.
2. Certain of the documents contained in the government's discovery production contain names and personal identifying information of individuals (hereinafter, the "Protected Material"). Such personal identifying information may include, but is not limited to, names, addresses, telephone numbers, driver's license numbers, social security numbers and financial account numbers. Any pages of discovery that contain no personal identifying information are not subject to this order.
3. The Protected Material is now and will forever remain the property of the United States. The Protected Material is entrusted to defense counsel only for purposes of representation in this case.
4. Counsel shall not give Protected Material or any copy of Protected Material to any person other than counsel's staff, investigator, or retained expert(s). The terms "staff," "investigator," and "expert" shall not be construed to describe any defendant or other person not either regularly employed by counsel or a licensed investigator or expert hired in this case.
5. Any person receiving Protected Material or a copy of Protected Material from counsel 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).
6. The defendants in this case may review the Protected Material and be aware of its contents, but shall not be given control of the Protected Material or any copies thereof. Notwithstanding the foregoing, counsel are permitted to provide each defendant with copies of documents otherwise classifiable as Protected Material so long as counsel completely redact all personal identifying information from those documents prior to providing them to a defendant.
7. The foregoing notwithstanding, after the Trial Confirmation Hearing in this case, counsel, staff, and investigator may make copies of the Protected Material for trial preparation and presentation. Any copies must, however, remain in the possession of counsel, staff, investigator, expert or the Court.
DATE: November 30, 2010 By: /s/ Matthew Stegman
DATE: November 30, 2010 /s/ Joseph J. Wiseman