STIPULATION AND [PROPOSED] PROTECTIVE ORDER

ALLISON CLAIRE, Magistrate Judge.

Plaintiff United States of America, by and through its attorneys of record, and defendant Paul Sanfilippo, by and through his counsel of record, hereby stipulate as follows:

1. The discovery in this case is voluminous, and portions of the discovery contain personal information including, but not limited to victims' names or other information that makes their identity readily apparent, residential addresses, social security numbers, telephone numbers, and email addresses (hereinafter "Protected Information").

2. In the absence of a protective order, numerous redactions would be necessary to avoid the unauthorized disclosure or dissemination of Protected Information to individuals not party to the court proceedings in this matter.

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 Information. Discovery that does not contain Protected Information is not subject to the Protective Order.

5. Defense counsel shall not give documents that contain Protected Information (or copies of such documents) to any person other than the defendant, the defendant's spouse, counsel's staff, investigator(s), or retained expert(s). The terms "staff," "investigator," and "expert" shall not be construed to describe any defendant or other person not: (1) regularly employed by counsel, or (2) hired by counsel as an independent contractor to work exclusively on this case, (3) licensed as an investigator, or (4) retained as an expert. The defendant, the defendant's spouse, and defense counsel's staff, contractor(s), investigator(s), and expert(s) shall not give documents that contain Protected Information (or copies of such documents) to any person. Copies of documents in which Protected Information has been redacted may be given to outside parties. In addition, all filings in which Protected Information is contained shall be made in accordance with Federal Rule of Criminal Procedure 49.1.

6. This order does not cover items whose disclosure is limited pursuant to 18 U.S.C. § 2258A(g)(2) and 18 U.S.C. § 3509(m). Such material that constitutes child pornography will remain within the custody and control of law enforcement at all times. Law enforcement will provide access to the material.

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

IT IS SO STIPULATED.