BENJAMIN B. WAGNER United States Attorney CAMIL A. SKIPPER Assistant U.S. Attorney 501 I Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2709 Facsimile: (916) 554-2900 Attorneys for Plaintiff UNITED STATES OF AMERICA
STIPULATION AND PROTECTIVE
ORDER BETWEEN UNITED STATES AND
RANDALL P. WESSAR
Plaintiff United States of America, by and through its attorney of record, Assistant United States Attorney CAMIL SKIPPER, and defendant RANDALL PAUL WESSAR, both individually and by and through his counsel of record, Assistant Federal Defender MICHAEL PETRIK, hereby stipulate as follows:
1. The discovery in this case is voluminous, and portions of the discovery contain large amount of personal information including, but not limited to, residential addresses, telephone numbers, and medical information ("Protected Information").
2. In the absence of a protective order, numerous redactions would be necessary to avoid the unauthorized disclosure or dissemination of Protected Information to individuals not party to the court proceedings in this matter.
3. By this stipulation, the parties jointly request that the Court issue a protective order pursuant to Rule 16(d) of the Federal Rules of Criminal Procedure and its general supervisory authority.
4. The Protective Order applies to all discovery containing Protected Information. Discovery that does not contain Protected Information is not subject to the Protective Order.
5. Defense counsel shall not give documents that contain Protected Information (or copies of such documents) to any person other than counsel's staff, investigator(s), or retained expert(s). The terms "staff," "investigator," and "expert" shall not be construed to describe any defendant or other person not: (1) regularly employed by counsel, or (2) licensed as an investigator, or (3) retained as an expert.
6. The defendant may review the Protected Information and be aware of its contents, but neither defense counsel nor counsel's staff, investigator(s), or expert(s) shall provide copies of Protected Information to defendant or allow defendant to copy documents containing Protected Information. Counsel may provide the defendant with copies of documents from which Protected Information has been redacted.
7. Defense counsel, counsel's staff, investigator(s), and expert(s) Nothing in this stipulation will be construed to prevent defense counsel, counsel's staff, investigator(s), or expert(s) a reasonable opportunity to prepare.
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