STIPULATION FOR PROTECTIVE ORDER

SHEILA K. OBERTO, Magistrate Judge.

WHEREAS, the discovery in this case involves information related to a tipster who seeks to remain anonymous and might be to harassment, threats, or other harms if his/her identity were to be divulged (the "Protected Information"); and

WHEREAS, the parties desire to have the Protected Information produced to undersigned defense counsel;

The parties agree that entry of a stipulated protective order is appropriate.

THEREFORE, Marco Antonio Lopez-Rubio ("Defendant"), by and through his counsel of record, Melissa Baloian ("Defense Counsel"), and the United States of America, by and through Assistant United States Attorney Laura D. Withers, hereby agree and stipulate as follows:

1. This Court may enter a protective order pursuant to Rule 16(d) of the Federal Rules of Criminal Procedure, and its general supervisory authority.

2. This Order pertains to the Protected Information, the Bates numbers pertaining to which will be specified when produced to Defense Counsel ("the discovery"). This Order also relates to any verbal communications between the government and Defense Counsel about the confidential tipster.

3. By signing this Stipulation and Protective Order, Defense Counsel agrees not to share any documents or other information, verbal or written, that contain Protected Information with anyone other than Defense Counsel, defense investigators, and support staff. Defense Counsel may permit Defendant to review un-redacted documents in the presence of his or her attorney, defense investigators, and support staff. The parties agree that Defense Counsel, defense investigators, and support staff shall not allow Defendant to copy Protected Information contained in the discovery.

4. Should Defendant become aware of or come to suspect the identity of the confidential tipster, he will take no steps to contact him/her or to ask another individual to contact him/her about the Protective Information or the discovery, except for Defense Counsel if such contact becomes necessary within the scope of his representation of Defendant.

5. The discovery and information therein may be used only 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 government. Defense Counsel will return the discovery to the government or certify that it has been destroyed 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 Defendant, employees, and other members of the defense team, and defense witnesses of the contents of this Stipulation and Order.

8. In the event that 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.

9. Defense Counsel reserves the right to later seek to have the terms of this Order modified or revoked. Defense Counsel agrees to return the discovery to the Government in its complete form if the terms of this Order are modified or revoked if so requested by the United States.

IT IS SO STIPULATED.

ORDER

IT IS SO ORDERED.