MELINDA HAAG (CABN 132612), United States Attorney, MIRANDA KANE (CABN 150630), Chief, Criminal Division, JAMES C. MANN (CABN 221603), Assistant United States Attorney, Oakland, CA, E-Mail: James.C.Mann@usdoj.gov, Attorneys for the United States of America
EDWARD A. SMOCK, Attorney for Defendant.
STIPULATION AND [PROPOSED] PROTECTIVE ORDER OAKLAND VENUE
DONNA M. RYU, Magistrate Judge.
With the agreement of the parties, and with the consent of defendant, the Court enters the following Order:
Defendant is charged with being a felon-in-possession of a firearm and ammunition and with obstruction of justice. Pursuant to defendant's request, the United States will produce electronic and hard copy information regarding defendant's obstruction of justice (hereinafter "INFORMATION") to defense counsel, in lieu of making it available for review only, pursuant to the following restrictions:
1. The United States will designate the INFORMATION as confidential and shall produce such discovery with the following notation: "WARNING: CONTENTS SUBJECT TO PROTECTIVE ORDER. UNAUTHORIZED COPYING OR VIEWING IS SUBJECT TO PUNISHMENT AS CONTEMPT OF COURT."
2. Except when being actively examined for the purpose of the preparation of the defense of defendant, the INFORMATION shall be maintained in a safe and secure place in defense counsel's office, which is accessible only to defense counsel, members of his or her law firm who are working with him or her to prepare defendant's defense, and his or her investigator(s). Defense counsel, members of his or her law firm, defendant, and the investigator(s) shall not permit any person access of any kind to the INFORMATION except as set forth below.
3. The following individuals may examine the INFORMATION for the sole purpose of preparing the defense of defendant and for no other purpose:
a) Counsel for defendant;
b) Members of defense counsel's law office who are assisting with the preparation of defendant's defense;
c) Defendant, but only in the presence of defense counsel or another authorized person listed in this paragraph, (defendant may not take or maintain the INFORMATION or copies thereof);
d) Investigators and experts retained by defendant to assist in the defense of this matter.
If defense counsel determines that additional persons are needed to review the INFORMATION, he or she must obtain a further order of the Court before allowing ...