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

EDMUND B. BRENNAN, Magistrate Judge.

IT IS HEREBY STIPULATED AND AGREED among the parties that the documents provided as discovery in this case to defense counsel are subject to a Protective Order. Defendants are charged with defrauding lending institutions by engaging in a fraudulent mortgage loan scheme and monetary transactions.

The parties agree that discovery in this case contains "Protected Information," which is defined here as including individuals' names, social security numbers, driver's license numbers, bank account numbers, financial account numbers, dates of birth, addresses, telephone numbers, and email addresses. The Protective Order signed in this case extends to all documents provided, including those concerning conduct not directly charged in the Indictment.

By signing this Stipulation, defense counsel agrees that the Protected Information is being entrusted to counsel only for the purposes of representing his respective defendant in this criminal case. Counsel for the defendants may make copies of discovery containing Protected Information. However, defense counsel agree not to share any documents that contain Protected Information with anyone other than their designated defense investigators, experts, and support staff. 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 be provided any copies of the Protected Information which has not been redacted. Any person receiving Protected Information or a copy of the Protected Information from counsel for the defendants 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).

In addition and notwithstanding the foregoing, after the trial date has been confirmed in this case, counsel, staff and/or the investigator 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.

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

IT IS SO ORDERED: