STIPULATION AND PROTECTIVE ORDER

JOHN A. MENDEZ, District Judge.

WHEREAS, the parties desire to prevent the unauthorized disclosure or dissemination of certain sensitive but unclassified information and the contents of certain sensitive but unclassified information documents (collectively, "Protected Information") to anyone not a party to the court proceedings in this matter, as provided below;

WHEREAS, the Protected Information includes information pertaining to victims or potential victims of federal crimes, including personal identifying information;

WHEREAS, such Protected Information shall be identified as sensitive and subject to a protective order at the time it is disclosed or made available for review by the defendant's counsel of record;

WHEREAS, the parties agree that entry of a stipulated protective order is appropriate, and that a private agreement is not appropriate in light of the nature of the Protected Information; and

WHEREAS, the defendant has counsel ("Defense Counsel") who wishes the opportunity to Stipulation & [Proposed] Protective Order 1 review the Protected Information;

Defendant PEDRO CARBAJAL-OSORIO and plaintiff United States of America, by and through their counsel of record, and Defense Counsel, each hereby agree and stipulate as follows:

1. This Court may enter protective orders pursuant to Rule 16(d) of the Federal Rules of Criminal Procedure, its general supervisory authority, and Local Rule 141.1.

2. This Order pertains to all information and documents provided and made available to Defense Counsel that is identified as sensitive and subject to a protective order in this case (i.e., the Protected Information).

3. Defense Counsel shall not disclose any of the Protected Information to any person other than his client, or attorneys, law clerks, paralegals, secretaries, experts, and investigators involved in the representation of his client.

4. The Protected Information may only be used in connection with the litigation of this case and for no other purpose.

5. Defense Counsel shall not disclose the Protected Information to third persons in violation of this agreement.

6. The defendant shall not disclose Protected Information disclosed to him by his Defense Counsel to third persons.

7. If Defense Counsel discloses any of the Protected Information in whatever format to any person described in paragraph (3) above, Defense Counsel shall provide such recipients with copies of this Order and advise that person that the Protected Information may only be used in connection with the litigation of this case and for no other purpose, and that an unauthorized use or disclosure of the Protected Information may constitute a violation of law and/or contempt of court.

8. In the event that the defendant obtains substitute counsel, undersigned Defense Counsel agrees to withhold the Protected Information from new counsel unless and until substituted counsel agrees to be bound by this Order.

9. Defense Counsel shall be responsible for advising their respective clients, employees, and other members of the defense team of the contents of this Stipulation/Order.

IT IS SO STIPULATED.

ORDER

The parties' proposed stipulated protective order, as set forth above, is HEREBY approved.

IT IS SO ORDERED.