STIPULATION AND [PROPOSED] PROTECTIVE ORDER

JON S. TIGAR, District Judge.

Pursuant to Federal Rule of Criminal Procedure 16(d), the United States and the defendant, through their respective undersigned counsel, hereby stipulate and agree that the Court should enter this proposed Protective Order requiring that the following restrictions shall apply to the discovery that the United States produces and designates as "Protected Material":

1. The Indictment charges the defendant with two counts of making and causing campaign contributions in the name of another, in violation of 52 U.S.C. § 30122 and 30109(d)(1)(D). Docket No. 1. In connection with this Indictment, the United States is in possession of numerous documents and records that are relevant to the defendant but that contain personally identifiable information (PII) of numerous third parties who may or may not be associated with the offenses described in the Indictment. Redacting all such information would be a time-consuming and resource-intensive task.

2. In order to expedite the production of discovery, therefore, the parties agree that the United States may designate certain discovery materials in this case as Protected Material (e.g., Bates-stamped "PROTECTED MATERIAL"). Any Protected Material so designated by the United States shall be subject to the terms of this Stipulation and Protective Order.

3. The following individuals (the "Defense Team") may access and examine the Protected Material under the conditions set forth herein for the sole purpose of preparing the defense and for no other purpose:

Counsel for the defendant shall advise the individuals on the Defense Team of the requirements and the restrictions in this Stipulation and Protective Order, as well as the Court's entry of the Protective Order.

4. The United States will produce one copy of the Protected Material to the Defense Team. The Defense Team will not make copies of the Protected Material unless (a) the United States provides written concurrence or (b) pursuant to further Court order. Similarly, the Defense Team shall not publicly offer, file, or lodge any Protected Material unless (a) the United States provides written concurrence, (b) pursuant to further Court order, or (c) it is done under seal.

5. The Defense Team shall not permit other persons access of any kind to the Protected Material and shall not share or give copies to other persons. The Defense Team shall use the Protected Material and its contents solely for the preparation, trial, direct appeal (if any), and collateral attack (if any) of this case and for no other purpose whatsoever. Additionally, the Defense Team will maintain the Protected Material in a secure location (e.g., locked drawer, cabinet, or safe) or secure electronic device (e.g., password-protected computer, memory stick). Further, the Defense Team will maintain a copy of this Stipulation and Protective Order with the Protected Material at all times.

6. The parties shall comply with Federal Rule of Criminal Procedure 49.1 with respect to the public filing or use of any discovery material containing personally identifiable or sensitive information, including: (1) Social Security numbers, (2) names of minor children, (3) dates of birth, and (4) financial account numbers. See Fed. R. Crim. P. 49.1. The parties shall also apply the requirements of Rule 49.1 when showing any discovery material containing personally identifiable or sensitive information to any third-party.

7. Any willful violation of this Stipulation and Protective Order shall constitute a criminal contempt of Court for which sanctions are provided by law.

8. This Stipulation and Protective Order shall remain in effect until the Defense Team returns the Protected Material (and any copies) to the United States. The Defense Team shall return the Protected Material (and any copies) to the United States within 30 days of the entry of judgment on all charges, unless a direct appeal is filed, in which case the Defense Team shall complete the return to the United States within 30 days of the date when the direct appeal is finally determined.

9. The parties shall meet and confer regarding any disputes arising under this Stipulation and Protective Order. The parties in this case have negotiated this Stipulation and Protective Order, which does not constitute a concession or waiver by either party regarding discovery procedures generally in this case or in any other or future case.

IT IS SO STIPULATED.

[PROPOSED] PROTECTIVE ORDER

IT IS SO ORDERED that disclosure of the above-described materials shall be restricted pursuant to the stipulation of the parties.