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U.S. v. Lara, 2:15-CR-00039 GEB. (2019)

Court: District Court, E.D. California Number: infdco20190416a82 Visitors: 17
Filed: Apr. 15, 2019
Latest Update: Apr. 15, 2019
Summary: STIPULATION TO MODIFICATION OF PROTECTIVE ORDER REGARDING DISCOVERY CONTAINING PERSONAL IDENTIFYING INFORMATION — AMENDED KENDALL J. NEWMAN , Magistrate Judge . IT IS HEREBY STIPULATED AND AGREED by the parties that the protective order filed in ECF Doc. 11 may be modified to allow defense counsel to provide a copy of the bates numbers listed below to the defendant with personal identifying information redacted, as described below. These pages relate to tax audits concerning the various tax
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STIPULATION TO MODIFICATION OF PROTECTIVE ORDER REGARDING DISCOVERY CONTAINING PERSONAL IDENTIFYING INFORMATION — AMENDED

IT IS HEREBY STIPULATED AND AGREED by the parties that the protective order filed in ECF Doc. 11 may be modified to allow defense counsel to provide a copy of the bates numbers listed below to the defendant with personal identifying information redacted, as described below. These pages relate to tax audits concerning the various taxpayers in this case. The defendant needs access to the dollar amounts in these reports to assist his counsel in preparing for trial.

The defendant agrees to store this information in a secure place, use care to ensure that information is not disclosed to third parties in violation of the protective order, and abide by all other terms of the protective order. All other terms of the protective order remain in effect.

The parties agree that defense counsel can disclose the following pages to the defendant, with all addresses, taxpayer identification numbers, social security numbers, dates of birth, and other personal identifying information redacted:

BATES TP # 801-816 TP 01 995-1009 TP 02 928-939 TP 03 831-847 TP 04 965-977 TP 05 1049-1055 TP 06 940-1034 TP 07 954-964 TP 08 817-830 TP 09 1010-1018 TP 10 1025-1034 TP 11 1056-1078 TP 12 1041-1048 TP 13 848-857 TP 14 858-865 TP 15 1348-1450 TP 16 1035-1040 TP 17 1019-1024 TP 18 898-905 TP 19 874-884 TP 20 978-994 TP 21

Mr. Lara agrees that he will make no other copies of these documents and will return them to defense counsel at the conclusion of this case. At the conclusion of this case, defense counsel agrees to obtain these documents from Mr. Lara, destroy all copies or return this information to the United States, and certify that this has been accomplished.

Dated: March 13, 2019. DAVID D. FISCHER Attorney for EMILIO LARA Dated: March 19, 2019. EMILIO LARA McGREGOR SCOTT United States Attorney Dated: March 13, 2019. MIRIAM HINMAN Assistant United States Attorney

IT IS SO ORDERED.

Source:  Leagle

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