STIPULATION AND [PROPOSED] PROTECTIVE ORDER BETWEEN THE UNITED STATES AND RUSLAN KIRILYUK

CAROLYN K. DELANEY, Magistrate Judge.

Plaintiff United States of America, by and through its counsel of record, and defendant RUSLAN KIRILYUK, by and through his new counsel of record, Olaf W. Hedberg, hereby stipulate as follows:

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

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

3. Defense counsel shall not disclose any of the discovery to any person other than their respective defendant/client, witnesses that they are interviewing or preparing for trial, or attorneys, law clerks, paralegals, secretaries, experts, and investigators involved in the representation of the defendant in connection to this criminal case.

4. The discovery and information therein may only be used in connection with the litigation of this case and for no other purpose. The discovery is now and will forever remain the property of the United States Government. Defense counsel will return the discovery or certify that it has been shredded at the conclusion of the case and defense counsel's document retention obligations.

5. In the event that the defendant obtains substitute counsel, undersigned defense counsel agrees to withhold the discovery from new counsel unless and until substituted counsel agrees to be bound by this Order.

6. 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.

7. If defense counsel makes, or causes to be made, any further copies of any of the discovery, defense counsel will inscribe the following notation on each copy: "U.S. Government Property; May Not Be Used Without U.S. Government Permission."

8. If defense counsel releases custody of any of the discovery, or authorized copies thereof, to any person described in paragraph three, defense counsel shall provide such recipients with copies of this Order and advise that person that the discovery is the property of the United States Government, that the discovery and information therein may only be used in connection with the litigation of this case and for no other purpose, and that an unauthorized use of the discovery may constitute a violation of law and/or contempt of court.

9. Defense counsel shall be responsible for advising his respective defendant, employees and other members of the defense team, and defense witnesses of the contents of this Stipulation/Order.

IT IS SO STIPULATED.

ORDER

IT IS SO FOUND AND ORDERED.