STIPULATION AND [PROPOSED] PROTECTIVE ORDER REGULATING DISCOVERY

CAROLYN K. DELANEY, District Judge.

IT IS HEREBY STIPULATED AND AGREED among the parties and their respective counsel, Jean M. Hobler and Christiaan H. Highsmith, Assistant U.S. Attorneys, representing plaintiff United States of America and Benjamin D. Galloway, Esq., representing defendant Devon G. Biggs, Jr., that discovery provided in this case to defense counsel is subject to a Protective Order.

The parties agree that discovery in this case contains "Protected Information," which is defined here as including photographs, videos, and other identifying information — such as social security numbers, driver license numbers, dates of birth, addresses, telephone numbers, financial information, tax records, and email addresses — of non-parties in this case. This Protective Order extends to all Protected Information provided in this case, including discovery related to conduct not directly charged in the indictment or in any future superseding indictments. In particular, this Protective Order extends to and covers photographs and videos — sexually explicit and otherwise — of individuals who are not a party to this case.

By signing this Stipulation and Protective Order, defense counsel agree not to share any Protected Information with anyone other than the defendant, defense counsel, and defense counsel's designated defense investigators and support staff. Defense counsel may disseminate Protected Information recovered from the defendant's cell phone to the defendant without limit; however, defense counsel may not distribute the Protected Information to anyone other than the defendant, defense investigators, and defense counsel support staff. In the event that the defendant substitutes counsel, undersigned defense counsel agree to withhold documents containing Protected Information from new counsel unless and until substituted counsel agree also to be bound by this order.

IT IS SO STIPULATED.

ORDER

IT IS HEREBY ORDERED that, based upon the agreement of the parties, the Court adopts the proposed stipulation regulating discovery in this case, no. 2:13-CR-0178 KJM.

IT IS SO ORDERED.