STIPULATION AND [PROPOSED] PROTECTIVE ORDER

EDMUND F. BRENNAN, District Judge.

WHEREAS, the parties desire to prevent the unauthorized disclosure or dissemination of certain sensitive but unclassified discovery materials to anyone not a party to the court proceedings in this matter;

WHEREAS, the parties agree that entry of a stipulated protective order is appropriate; and

WHEREAS, the defendant DONALD MOYER III has counsel who wishes the opportunity to review the discovery,

Defendant DONALD MOYER III and Plaintiff United States of America, by and through their counsel of record, 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, and its general supervisory authority.

2. This Order pertains to all discovery provided to or made available to Defense Counsel as part of discovery in this case (hereafter, collectively known as "the discovery").

3. Defense Counsel shall not disclose any of the discovery 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 discovery and information therein may only be used 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 United States Government. Defense Counsel will return the discovery to the Government or certify that it has been shredded at the conclusion of the case.

5. 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.

6. If Defense Counsel releases custody of any of the discovery, or authorized copies thereof, to any person described in paragraph (3), Defense Counsel shall provide such recipients with copies of this Order and advise that person that the discovery is the property of the United States Government, that the discovery and information therein may only be used in connection with the litigation of this case and for no other purpose, and that an unauthorized use of the discovery may constitute a violation of law and/or contempt of court.

7. Defense Counsel shall be responsible for advising his client, employees, and other members of the defense team of the contents of this Stipulation/Order.

IT IS SO STIPULATED.

ORDER

For good cause shown, the stipulation of counsel in criminal case no. 2:14-CR-00264-EFB concerning sensitive information in discovery is approved, and IT IS SO ORDERED.