United States District Court, E.D. California
Dumitru Martin, Defendant, represented by John Paul Balazs,
Law Office of John P. Balazs & William John Portanova,
William J. Portanova, Attorney At Law.
Anamaria Cruceru, Defendant, represented by Jerome Price,
Office Of The Federal Defender & Linda C. Allison, Federal
Public Defender's Office.
Constantin Schiller, Defendant, represented by Richard T.
Dudek, Law Office Of Richard T. Dudek.
Marcelle Banaga, Defendant, represented by Alin Cintean, Law
Offices Of Alin Cintean.
Plaintiff, represented by Michael M. Beckwith, United States
Attorney's Office, Todd A. Pickles, United States
Attorney's Office & Kevin Christopher Khasigian, United
States Attorney's Office.
STIPULATION AND PROTECTIVE ORDER
L. NUNLEY, District Judge.
United States of America, by and through its counsel of
record, and defendants Dumitru Martin, Constantin Schiller,
and Marcelle Banaga, by and through their counsel of record,
hereby stipulate and jointly request the Court entered the
following protective order ("Order"):
Court may enter protective orders pursuant to Rule 16(d) of
the Federal Rules of Criminal Procedure, its general
supervisory authority, and Local Rule 141.1.
discovery produced or to be produced by the United States in
this case includes materials that contain financial or
personal matters with respect to one or more defendants as
well as information about confidential human sources of the
Federal Bureau of Investigation.
parties and their counsel of record shall not provide or
disclose any of the discovery in this case, including the
contents thereof, to any person other than the defendant, or
attorneys, law clerks, paralegals, secretaries, experts,
investigators, and translator or interpreters, involved in
the representation of their clients, as well as the Court and
its staff and personnel.
discovery and information contained therein may only be used
in connection with the litigation of this case and for no
other purpose. At the conclusion of the case, including after
any appeal or collateral attack, including a motion under 28
U.S.C. Â§ 2255 or Â§ 2241, is decided, counsel for defendants
will either return to the United States all discovery,
including any copies provided to the defendant, or certify
that it has been shredded or otherwise destroyed at the
conclusion of the case.
Counsel for the defense will store the discovery in a secure
place and will use reasonable care to ensure that it is not
disclosed to third persons in violation of this stipulation
counsel releases custody of any of the discovery, or
authorized copies thereof, to any person described in
paragraph (3), counsel shall provide such recipients with
copies of this Order and advise that person that the
discovery and information therein may only be used in
connection with the litigation of this case and for no other
purpose, that it must be maintained in a secure location, and
that an ...