January 3, 2014
UNITED STATES OF AMERICA, Plaintiff,
CLIFFORD DALE BERCOVICH and HOWARD WEBBER, Defendants.
MELINDA HAAG (CABN 132612), United States Attorney, J. DOUGLAS WILSON (DCBN 412811), Assistant United States Attorney, Chief, Tax Division, CYNTHIA STIER (DCBN 423256), Assistant United States Attorney, San Francisco, California, Attorneys for the United States.
ELIZABETH FALK, Counsel for Howard Webber.
STIPULATION AND [PROPOSED] PROTECTIVE ORDER
RICHARD SEEBORG, District Judge.
The United States and the defendant, Howard Webber, through undersigned counsel, hereby stipulate and agree as follows:
1. The United States is prepared to produce to defendant's counsel of record in this matter Memorandums of Interview Bates Nos. US15353 through US15406 and US15937 through US15973.
2. Defendant will not discuss the Memorandums of Interview, or the contents thereof, with any other individual except his counsel of record and defense team. Defendant's counsel of record may discuss the contents of the Memorandums of Interview for the purpose of preparing and evaluating the defense in this proceeding.
3. The documents described above shall not be copied at all unless copying is necessary for preparation of the defense in this proceeding.
4. Any copy of the materials stated herein shall be accompanied by a copy of this Stipulation and Order. No document or copy thereof shall be left with any defense witness.
5. Defendant's pretrial release conditions shall be amended to include defendant's compliance with this protective order, and appropriate sanctions may be imposed for any violation of this condition.
In light of the stipulation and agreement of the parties to this action, and good cause appearing therefor, it is HEREBY ORDERED that disclosure of the above-described information shall be restricted as set forth in Paragraphs 1 through 5 above.