STIPULATION AND [PROPOSED] PROTECTIVE ORDER BETWEEN THE UNITED STATES AND GLENN NATHAN LITTON

EDMUND F. BRENNAN, Magistrate Judge.

STIPULATION

WHEREAS, the discovery in this case contains a large amount of personal information including but not limited to Social Security numbers, dates of birth, drivers license numbers, bank account numbers, telephone numbers and residential addresses ("Protected Information"); and

WHEREAS, the parties desire to avoid both the necessity of large scale redactions and the unauthorized disclosure or dissemination of this information to anyone not a party to the court proceedings in this matter, Plaintiff United States of America, by and through its counsel of record, and defendant GLENN NATHAN LITTON, aka GLENN NATHAN WILLIAMS, by and through his counsel of record, hereby 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 Stipulation and 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 attorneys, law clerks, paralegals, secretaries, experts, and investigators involved in the representation of the defendant in connection to this criminal case. Defense Counsel may permit the defendant or witnesses that he/she is interviewing or preparing for trial to view unredacted documents in the presence of defense counsel, defense investigators and support staff. The parties agree that Defense Counsel, defense investigators and support staff shall not allow the defendant or any witness to copy or otherwise retain Protected Information contained in the discovery.

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. Upon request of the government, defense counsel will return the discovery or certify that it has been shredded at the conclusion of the case and defense counsel's document retention obligations.

5. In the event that the defendant obtains substitute counsel, undersigned defense counsel agrees to withhold the discovery from new counsel unless and until substituted counsel agrees to be bound by this order.

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.

8. If defense counsel releases custody of any of the discovery, or authorized copies thereof, to any person described in paragraph three, 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.

Remainder of Page Intentionally Left Blank

9. Defense counsel shall be responsible for advising his or her respective defendant, employees and other members of the defense team, and defense witnesses of the contents of this Stipulation/Order.

IT IS SO STIPULATED.

ORDER

IT IS SO FOUND AND ORDERED.