STIPULATION AND [PROPOSED] PROTECTIVE ORDER

EDMUND F. BRENNAN, Magistrate Judge.

Plaintiff United States of America, by and through its attorney of record, and defendant's counsel, hereby stipulate as follows:

1. The discovery in this case contains personal information including, but not limited to victims' and witnesses' names or other information that makes their identity readily apparent, residential addresses, and telephone numbers (hereinafter "Protected Material").

2. The Protected Material is now and will forever remain the property of the United States. The Protected Material is entrusted to defendant's counsel only for purposes of representation of his client in this case.

3. By this stipulation, the parties jointly request that the Court issue a protective order pursuant to Rule 16(d) of the Federal Rules of Criminal Procedure and its general supervisory authority.

4. The Protective Order applies to all discovery containing Protected Material. Discovery that does not contain Protected Material is not subject to the Protective Order.

5. Defense counsel shall not give the Protected Material to any person other than counsels' staff assisting them in the present case. The term "staff" shall explicitly include attorney, paralegals, administrative employees and investigators assisting defendant's counsel in the present case and exclude any other person other than those specifically described in this paragraph.

6. Any person receiving access to the Protected Material from defendant's counsel shall be bound by the same obligations as defense counsel and, further, may not give the Protected Material to anyone.

7. Defense counsel may use any and all of the Protected Material in the vigorous defense of his client in the instant case in any manner he deems essential to adequately represent his client (i.e., in motions that are filed under seal, if necessary, in ex-parte applications as may be needed, reproducing and summarizing the protected materials for use in trial preparation summaries, exhibits and as evidence, as may be needed), consistent with the Protective Order as it shall be originally prepared and signed. In the event defense counsel needs to use the Protected Material in a manner not authorized under the present Proposed Protective Order and consistent with their obligations under the Sixth Amendment to the United States Constitution, defense counsel shall be entitled to seek to have the order amended by the District Court, after having given notice to counsel for the government.

8. Defense counsel is authorized to review with his client any and all portions of the Protected Material. However, defense counsel and any members of his staff are prohibited from giving the defendant: the Protected Materials, themselves; copies of the Protected Material; or copies of excerpts of the Protected Material. This prohibition will not extend to the defendant viewing the Protected Material in open court should these materials be used in the litigation of this case.

6. Nothing in this stipulation will be construed to prevent defense counsel, counsel's staff, contractor(s), investigator(s), or expert(s) a reasonable opportunity to prepare.

IT IS SO STIPULATED.

Pursuant to the stipulation of the parties and good cause appearing, the proposed protective order is APPROVED AND SO ORDERED.