STIPULATION AND [PROPOSED] PROTECTIVE ORDER RE: DISCOVERY CONTAINING PERSONAL IDENTIFYING INFORMATION

EDMUND F. BRENNAN, Magistrate Judge.

IT IS HERBEY STIUPLATED AND AGREED by the parties that some of the materials provided as discovery in this case to defense counsel are subject to a Protective Order. Defendants are charged with offenses related to an alleged tax refund fraud scheme.

The parties agree that discovery in this case contains "Protected Information," including but not limited to, victim and witness tax information and records, social security numbers, addresses, bank account information, and dates of birth. The Protective Order extends to all materials provided to the defense, including those concerning conduct not directly charged in the Indictment.

Through this Stipulation, defense counsel agree that the Protected Information is entrusted to counsel only for the purposes of representing their clients in this criminal case and for no other purpose. Further, defense counsel agree not to share any documents that contain Protected Information with anyone other than designated defense investigators, experts, and support staff. Defense counsel will have a duty to inform their defense investigators, experts, and support staff of this Order and provide them with a copy of it. Defense counsel may permit the defendants to review the Protected Information and be aware of its contents, but defendants shall not be given control of the Protected Information or provided any copies of the Protected Information that have not been redacted of the Protected Information. Any person receiving Protected Information or a copy of the Protected Information from defendants' counsel shall be bound by the same obligations as counsel and further may not give the Protected Information to anyone (except that the protected documents shall be returned to counsel).

Counsel agree to store Protected Information in a secure place and to use care to ensure that information is not disclosed to third parties in violation of this agreement. At the conclusion of the case, defense counsel agree to destroy all copies of Protected Information or to return the Protected Information to the United States and certify that this has been accomplished.

Notwithstanding the foregoing, counsel, staff and/or the investigators for the defendants may make copies of the Protected Information for trial preparation and presentation. Any copies must, however, remain in the possession of counsel, investigator, staff, expert or the court.

Nothing in this Stipulation and Protective Order prevents defense counsel or the defendants from maintaining unredacted copies of records concerning the defendants' own Protected Information.

In the event that the defendant substitutes counsel, undersigned defense counsel agrees to withhold these documents form new counsel unless and until substituted counsel agrees also so be bound by this order.

IT IS SO ORDERED.