STIPULATION AND PROTECTIVE ORDER BETWEEN UNITED STATES AND DEFENDANT

JOHN A. MENDEZ, District Judge.

WHEREAS, the discovery in this case is voluminous and contains a large amount of personal information including but not limited to Social Security numbers, dates of birth, 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;

The parties agree that entry of a stipulated protective order is appropriate.

THEREFORE, the defendant, by and through his counsel, and Plaintiff, the United States of America, 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 counsel for the defendant as part of discovery in this case (hereafter, collectively known as "the discovery").

3. By signing this Stipulation and Protective Order, counsel for the defendant agrees not to share any documents that contain Protected Information with anyone other than co-counsel and designated defense investigators and support staff. Counsel for the defendant may permit the defendant to view unredacted documents in the presence of his attorney, defense investigators and support staff. The parties agree that counsel for the defendant, defense investigators and support staff shall not allow the defendant to copy Protected Information contained in the discovery. The parties agree that counsel for the defendant, defense investigators, and support staff may provide the defendant with copies of documents from which Protected Information has been redacted.

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. Counsel for the defendant will return the discovery to the Government or certify that it has been shredded at the conclusion of the case.

5. Counsel for the defendant 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. Counsel for the defendant shall be responsible for advising his client, employees, and defense witnesses of the contents of this Stipulation/Order.

7. In the event that the defendant substitutes counsel, undersigned counsel for the defendant agrees to withhold discovery from new counsel unless and until substituted counsel agrees also to be bound by this Order.

IT IS SO STIPULATED.

IT IS SO FOUND AND ORDERED.