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United States v. Zuk
United States District Court, N.D. California, San Francisco Division
July 13, 2016
UNITED STATES OF AMERICA,
MARINA ZUK, Defendant.
Zuk, Defendant, represented by Andrew DePue Allen, Morgan,
Lewis and Bockius LLP & Martin Aaron Schainbaum, Martin A.
Plaintiff, represented by Jose Apolinar Olivera, U.S.
STIPULATION AND [PROPOSED] DISCLOSURE & PROTECTIVE
THELTON HENDERSON, District Judge.
United States of America (the "Government"), and
defendant Marina Zuk, hereby stipulate as follows:
1. Defendant Marina Zuk was charged by indictment on April 7,
2015, with three counts of making and subscribing a false tax
return in violation of 26 U.S.C. Â§ 7206(1).
2. The Government has provided Defendant with more than 7,
000 pages of discovery, the bulk of the discovery in this
case. The Government possesses additional discovery related
to an individual with the initials M.B. This additional
discovery contains private financial information and
confidential tax return and taxpayer return information
within the meaning of Title 26, United States Code, Section
6103(b). Disclosure of such tax return and taxpayer return
information is governed by Title 26, United States Code,
Section 6103(a), which mandates that returns and return
information shall be confidential, except as authorized by
3. Section 6103(h)(4)(D) of Title 26 permits disclosure to
the Defendant, by order of the court, of another's tax
return and taxpayer information as required under Rule 16 of
the Federal Rules of Criminal Procedure and the Jencks Act,
18 U.S.C. Â§ 3500.
4. The Government intends to provide defense counsel with
private financial information and tax return and return
information of M.B. that constitutes Rule 16 or Jencks Act
discovery, which will likely be disclosed to Defendant.
5. The parties agree that the additional discovery regarding
M.B. identified above will be provided subject to the
a. Pursuant to Rule 16(d)(1) of the Federal Rules of Criminal
Procedure and Title 28, United States Code, Section 1651,
unauthorized disclosure of discovery material and information
contained therein to nonlitigants is prohibited under the
following provisions (when the term "Defendant" is
used, said term encompasses an attorney for the Defendant):
i. The additional discovery regarding M.B. identified above,
remains the property of the Government and is being produced
as required by Rule 16 and the Jencks Act in preparation for
or in connection with any stage of the proceedings in this
case. All such materials and all copies made thereof shall be
returned to the United States Attorney's Office, Tax
Division, unless otherwise ordered by the Court or agreed
upon by the parties, at the occurrence of the last of the
1. The completion of all appeals, habeas corpus proceedings,
clemency or pardon proceedings, or other post-conviction
2. the conclusion of the sentencing hearing; or
3. the earlier resolution of charges against the ...
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