MARK. W. GIRDNER, SBN#224714 Law Offices of Mark W. Girdner, Modesto, CA, Attorneys for Defendant, HENRY STANLEY, JR.
MICHELLE RODRIGUEZ, Assistant U.S. Attorney, Attorney for Plaintiff.
STIPULATION AND ORDER FOR PROTECTIVE ORDER REGARDING DEFENSE FORENSIC COMPUTER EXAMINATION
KIMBERLY J. MUELLER, Judge.
THE PARTIES STIPULATE, through their respective counsel, Michelle Rodriguez, Assistant United States Attorney, and Mark W. Girdner, Attorney for defendant Mr. Stanley, to the following proposed protective order governing the defense expert's forensic examination of computer data seized in this case.
In order to advise the defendant adequately, the defense case requires a forensic evaluation by Mark W. Girdner and other material 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. They ask the Court to approve the proposed order.
Pursuant to the parties' agreement, the Court approves the attached protective order.
IT IS SO ORDERED.
IT IS HEREBY ORDERED AS FOLLOWS:
1. The United States Department of Homeland Security, Immigration and Customs Enforcement agents shall make a duplicate copy of the hard drive and any other storage media available for the defense attorney analysis.
2. The duplicate copies of the hard drive and storage media shall be made available for defense counsel, Mark W. Girdner, or another member of the defense team, and to defendant's expert, to review at the Sacramento High Tech Task Force offices in Sacramento for the purpose of preparing the defense of the above-entitled action. The images on the hard drive and storage media shall not be viewed by another person on behalf of the defense.
3. A private room will be provided for the defense examination. No government agents will be inside the room during the examination.
4. The attorney will be permitted to bring whatever equipment, books, or recording he believes may be ...