IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
March 25, 2011
UNITED STATES OF AMERICA,
TERENCE ALEXANDER JONES,
The opinion of the court was delivered by: Gregory G. Hollows United States Magistrate Judge
BENJAMIN B. WAGNER United States Attorney SAMANTHA S. SPANGLER Assistant U.S. Attorney 501 I Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2792
STIPULATION FOR PROTECTIVE ORDER;
Plaintiff United States of America and defendant Terence Alexander Jones, through undersigned counsel, hereby stipulate that the Court may enter this protective order, under the following terms and conditions:
1) The government has agreed to provide defense counsel with an advance copy of the discovery in this case, unredacted.
2) Defense counsel agrees that she will not provide to the defendant any report or other discovery document that contains the name and/or address and/or telephone number of any individual whose mail was stolen or whose car was stolen. The defendant may see the documents, but he may not make any notes of any of the names or other personal identifying information contained in the documents.
Alternatively, defense counsel may choose to provide the defendant a redacted copy of the discovery, after first allowing the undersigned prosecutor an opportunity to view the proposed redacted version of the discovery and comment upon the quality of the redactions.
3) The defendant will not personally be involved in any attempt to contact any of the individuals whose mail or car was stolen. Instead, that contact may be made by the Federal Defender's Investigator, who must make it clear to the individual that he works for the Federal Defender's Office, who represents the defendant. If that individual does not wish to speak to the Investigator, the Investigator will honor that desire.
4) Both parties agree that the Court (the duty Magistrate Judge) may issue an order upon this Stipulation.
It is so stipulated.
Good cause appearing, the same is hereby ORDERED.
Gregory G. Hollows
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