STIPULATION AND PROTECTIVE ORDER BETWEEN THE UNITED STATES AND DEFENDANT CESAR FABIAN GUERRERO-TORRES

LAWRENCE J. O'NEILL, District Judge.

The parties agree that entry of a stipulated protective order.

Therefore, Defendant CESAR FABIAN GUERRERO-TORRES, by and through his counsel of record ("Defense Counsel"), and the United States of America, by and through Assistant United States Attorney Kimberly A. Sanchez, hereby agree and stipulate as follows:

1. This Court may enter a protective order pursuant to Rule 16(d) of the Federal Rules of Criminal Procedure, and its general supervisory authority.

2. This Order pertains to all discovery provided to or made available to Defense Counsel as part of discovery in this case, and documents produced subsequent to the date of entry of this Order (hereafter, collectively known as the "discovery").

3. By signing this Stipulation and Protective Order, Defense Counsel and Defendant agree not to share any discovery provided by the Government with anyone other than the Defendant, Defense Counsel attorneys, designated defense investigators, and support staff. The parties agree that Defense Counsel, defense investigators, and support staff may provide the Defendant with copies of discovery.

4. The discovery and information therein may be used only in connection with the litigation of this case and for no other purpose.

5. Defense Counsel 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 agreement.

6. Defense Counsel shall be responsible for advising the Defendant, employees, and other members of the defense team, and defense witnesses of the contents of this Stipulation and Order.

IT IS SO ORDERED.