STIPULATION AND [PROPOSED] ORDER

KIMBERLY J. MUELLER, District Judge.

The United States, through its undersigned counsel, and Defendant, both individually and through his undersigned counsel, hereby stipulate as follows:

1. On January 2, 2019, the defendant, Tariq Arrahamann Majid, was charged by criminal complaint with one count of Exploitation of a Minor (18 U.S.C. § 2251(a)) and one count of Receiving Material Involving the Sexual Exploitation of a Minor (18 U.S.C. § 2252(a)(2)). The complaint alleged that the defendant video recorded and photographed minors while he sexually abused them.

2. The defendant appeared before Magistrate Judge Allison Claire on January 2, 2019, and he was ordered detained as a flight risk and danger to the community.

3. The Grand Jury returned an indictment against the defendant on January 10, 2019, charging him with two counts of Exploitation of a Minor (18 U.S.C. § 2251(a)) and two counts of Receiving Material Involving the Sexual Exploitation of a Minor (18 U.S.C. § 2252(a)(2)).

4. The discovery in this case identifies multiple minor victims who claim to have been sexually abused by the defendant. These are allegations that have not yet been proven in any court, state or federal.

5. Although the indictment currently charges only two minor victims (John Does #1 and #2), the discovery provided to the defense identifies other alleged victims, including two who are named as "John Does #3 and #4." The government has informed the defense that it considers these individuals to be potential witnesses in this case.

6. On or about June 28, 2019, the defendant wrote a letter to John Does #3 and #4, who are both minors. The parents of John Does #3 and #4 provided the letter to law enforcement. A copy of that letter is included as an exhibit to the government's motion for a protective order, filed on July 20, 2019.

7. The government has received information from investigators that the parents of John Does #3 and #4 do not want their children to be contacted by defendant or any of his representatives, nor do they want to be contacted by defendant or his representatives.

8. The defendant has no children of his own, nor does he have any familial relationships with minors who he might otherwise have a right to associate with.

9. In light of the foregoing, the parties hereby stipulate and agree that the defendant shall not communicate with any minor through any means, including but not limited to, phone communication, in-person jail visits, written communication, and communication through third parties, including a minor's parents, during the pendency of this case.

10. The parties further stipulate and agree that the defendant and members of the defense team shall refrain from communicating with the parents of John Does #3 and #4, based on their expressed desire to be protected from such communications.

Dated: July 24, 2019 McGREGOR W. SCOTT United States, Attorney By: /s/ Michele Beckwith Michele Beckwith Assistant United States Attorney Dated: July 25, 2019 /s/ Linda Allison Linda Allison Counsel for Defendant Dated: July 25, 2019 /s/ TARIQ ARRHAMANN MAJID Defendant

[PROPOSED] ORDER

The Court, having reviewed the government's motion and the parties' stipulation, finds good cause for the following order.

The defendant shall not communicate with any minor through any means, including but not limited to, phone communication, in-person jail visits, written communication, and communication through third parties, including a minor's parents, during the pendency of this case.

Further, the defendant and members of the defense team shall not communicate with John Doe #3 and #4 (both of whom are minors) or their parents during the pendency of this case.

IT IS SO ORDERED.