The opinion of the court was delivered by: John A. Mendez United States District Court Judge
STIPULATION AND PROTECTIVE ORDER REGARDING DISSEMINATION OF DISCOVERY DOCUMENTS CONTAINING PERSONAL IDENTIFICATION INFORMATION
IT IS HEREBY STIPULATED AND AGREED among the parties and their respective counsel, Todd D. Leras and Paul Hemesath, Assistant United States Attorneys, on behalf of the government, and Attorney Daniel F. Koukol on behalf of defendant Peter Woodard, that the documents to be provided as discovery in this case are subject to a Protective Order.
Defendant is charged with various mail and wire fraud offenses related to an alleged scheme to acquire real property on behalf of numerous investors. The parties agree that discovery in the case necessarily contains Protected Information. The phrase "Protected Information" as used in this stipulation and order includes investor Social Security Numbers, Driver's License Numbers, dates of birth, addresses, telephone numbers, e-mail addresses, and any other personal or financial identifying information. This Protective Order extends to all documents provided by the government to defense counsel in this case, including those items related to conduct not charged in the Indictment.
By signing this Stipulation and Protective Order, defense counsel agrees not to share any documents containing Protected Information in unredacted form with any person other than primary counsel, assisting counsel, designated defense investigators, and support staff. Defense counsel may allow the client to view unredacted documents in the presence of his attorney, an investigator, and/or appropriate support staff.
The parties further agree that defense counsel, an investigator, and support staff shall not permit defendant to copy, either in writing or by other means, Protected Information contained in the discovery. Defense counsel, an investigator and support staff may provide the client with copies of documents from which all Protected Information has been redacted.
In the event that defendant substitutes counsel, the undersigned attorney agrees to withhold documents containing Protected Information from new counsel until such time as substituted counsel agrees to be bound by this Protective Order.
This stipulation and protective order has been provided to defense counsel for review. Following review of its contents, Assistant U.S. Attorney Todd Leras has been authorized via e-mail to sign this stipulation on behalf of Attorney Daniel F. Koukol.
DATED: February 4, 2013 By: /s/ Todd D. Leras TODD D. LERAS Assistant U.S. Attorney DATED: February 4, 2013 By: /s/ Paul Hemesath PAUL HEMESATH Assistant U.S. Attorney DATED: February 4, 2013 By: /s/ Todd D. Leras for DANIEL F. KOUKOL Attorney for Defendant PETER WOODARD
FOR GOOD CAUSE SHOWN, pursuant to the stipulation of counsel, Protected Information provided to defense counsel by the government as discovery in Case Number S-12-315 JAM shall:
1. Be shared in unredacted format only among primary counsel, assisting counsel, a designated defense investigator and support staff;
2. Be viewed by a defendant in unredacted format only in the presence of his attorney, an investigator, and/or appropriate support staff; and
3. Be provided to defendant only in a copy from which all Protected Information has been redacted.
No person shall permit defendant to copy, either in writing or by other means, Protected Information contained in the discovery. No person shall provide substitute counsel with documents containing Protected Information until such time as ...