United States v. Martin

          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.

          USA, 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

          TROY L. NUNLEY, District Judge.

         STIPULATION

         Plaintiff 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"):

         1. This 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.

         2. The 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.

         3. The 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.

         4. The 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. § 2255 or § 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.

         5. 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 and order.

         6. If 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 ...