The opinion of the court was delivered by: Kendall J. Newman United States Magistrate Judge
DANIEL J. BRODERICK, Bar #89424 Federal Defender DENNIS S. WAKS, Bar# 142581 Supervising Assistant Federal Defender Designated Counsel for Service 801 I Street, 3rd Floor Sacramento, California 95814 Telephone: (916) 498-5700 Attorney for Defendant JERRY ARBERT POOL
STIPULATION AND [PROPOSED ORDER] FOR PROTECTIVE ORDER REGARDING DEFENSE FORENSIC COMPUTER EXAMINATION
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, Michelle Prince, Assistant United States Attorney, attorney for Plaintiff, and Dennis Waks, Assistant Federal Defender, attorney for Mr. Pool, that the Court should approve the proposed protective order governing the defense expert's forensic examination of the computer data in this case.
In order to advise the defendant adequately, the defense in this case requires a further forensic evaluation by a knowledgeable expert of the computer hard drives which the government alleges contain images of child pornography. The parties have agreed that the attached proposed order should govern the defense examination of the computer media and request that the Court approve the attached proposed order.
Case 2:09-cr-00015-EJG Document 83 Filed 04/15/11 Page 3 of 6
DANIEL J. BRODERICK, #89424 Federal Defender DENNIS S. WAKS, BAR #142581 Supervising Assistant Federal Defender 801 I Street, 3rd Floor Sacramento, California 95814 Telephone: (916) 498-5700 Attorney for Defendant JERRY ARBERT POOL
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, ) CR.S. 09-0015-EJG
Plaintiff, )) PROTECTIVE ORDER CONCERNING
v. ) DIGITAL MEDIA CONTAINING ) CHILD PORNOGRAPHY