STIPULATION AND PROTECTIVE ORDER

LAWRENCE J. O'NEILL, Chief District Judge.

STIPULATION REGARDING DISCOVERY AND PROTECTIVE ORDER

The United States of America, by and through MCGREGOR W. SCOTT, United States Attorney, and Melanie L. Alsworth, Assistant United States Attorney, and the defendant, through his respective counsel of record, 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 Order pertains to all documents, recordings and statements of witnesses provided to or made available to Defense Counsel as part of discovery in this case produced on or after the date of this order and beginning with Bates Number 1063 or to comply with trial obligations pursuant to Title 18, United States Code, Section 3500 (the Jenck's Act), or to comply with Brady and Giglio obligations.

3. By signing this Stipulation and Protective Order, Defense Counsel agrees not to share any documents, recordings or statements of witnesses with anyone other than designated defense investigators and support staff. Defense Counsel may review the contents of documents, recordings and witness statements with the defendant, and the parties agree that neither Defense Counsel, defense investigators nor support staff shall allow the defendant to copy or retain copies of such information.

4. By signing this Stipulation and Protective Order, Defense Counsel agrees not to disclose the identity of any witness to anyone other than the defendant, designated defense investigators and support staff. Defense counsel agrees that he will not provide the defendant with any documentation identifying the witnesses. Defense Counsel agrees to admonish defendant not to disclose the identities of any witnesses.

5. The discovery and information provided by the Government 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 to the Government or certify that it has been shredded at the conclusion of the case.

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

8. In the event that the defendant substitutes counsel, undersigned Defense Counsel agrees to withhold discovery from new counsel unless and until substituted counsel agrees also to be bound by this Order.

IT IS SO STIPULATED.

IT IS SO ORDERED.