MELINDA HAAG (CABN 132612) United States Attorney, MIRANDA KANE (CABN 150630) Chief, Criminal Division, ADAM A. REEVES (NYBN 2363877) ROBERT S. LEACH (CABN 196191) Assistant United States Attorneys, San Francisco, California, Attorneys for Plaintiff.
LAW OFFICES OF BRIAN H. GETZ BRIAN H. GETZ, ESQ., Counsel for Defendant Karim Iskander Bayyouk.
STIPULATION AND [PROPOSED] PROTECTIVE ORDER
EDWARD M. CHEN, District Judge.
The United States and the defendant in this action, through undersigned counsel, hereby stipulate and agree as follows:
1. The United States is prepared to produce to the defendant witness statements and reports governed by 18 U.S.C. § 3500, including grand jury testimony, and other grand-jury matters in advance of trial.
2. Federal Rule of Criminal Procedure 6(e)(3)(E) provides that the Court "may authorize disclosure - at a time, in a manner, and subject to any other conditions that it directs - of a grand-jury matter: (i) preliminary to or in connection with a judicial proceeding." The parties request that the Court issue an order authorizing such disclosure.
3. Possession of copies of the witness statements and reports shall be limited to the defendant and his attorneys, including any investigators, paralegals, law clerks, assistants, and other persons who are within the attorney-client privilege (hereinafter collectively referred to as "members of the defense team"). The defendant, his attorneys, and members of his defense team shall use the witness statements and reports only for the purpose of defending against the allegations in the Indictment. The defendant, his attorneys, and members of his defense team shall not provide copies of the witness statements and reports to other persons.
4. At the conclusion of this proceeding, the defendant, his attorneys, and members of his defense team shall return to the government all copies of the witness statements and reports.
In light of the stipulation and agreement of the parties to this action, and good cause appearing, it is HEREBY ORDERED that the United States is authorized to disclose grand-jury matters to the defendant, including the grand jury testimony of witnesses intended to be called at the trial. It is FURTHER ORDERED that use of any witness statements and reports ...