STIPULATION AND PROTECTIVE ORDER BETWEEN THE PARTIES REGARDING DISCOVERY

KENDALL J. NEWMAN, Magistrate Judge.

IT IS HEREBY STIPULATED AND AGREED between plaintiff United States of America and defendant DASHAWN WILLIAMS, in pro per, and his stand-by counsel, Scott Tedmon, 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 discovery bates stamped with "Standby_Counsel" or "Williams_Pro_Se" provided to or made available after February 10, 2016.

3. Stand-by counsel nor any assigned defense investigator or defense paralegal shall not disclose any of the "Standby_Counsel" discovery to any person, including Dashawn Williams, the defendant in pro per, other than witnesses that they are interviewing or preparing for trial, or attorneys, law clerks, paralegals, secretaries, experts, and investigators involved in the representation of the defendant in connection to this criminal case. "Williams_Pro_Se" discovery shall only be disclosed to the defendant, Dashawn Williams, in pro per. Dashawn Williams, the defendant in pro per, shall not disclose any of the "Williams_Pro_Se" discovery to any person other than his stand-by counsel or assigned defense investigator or defense paralegal.

4. All of the discovery in this case 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. Stand-by counsel and Dashawn Williams, the defendant in pro per, will return the discovery or certify that it has been shredded at the conclusion of the case and stand-by counsel's document retention obligations.

5. In the event that the defendant obtains substitute stand-by counsel, undersigned defense counsel agrees to return all discovery provided under this order to government counsel, in order that the government may arrange for substituted counsel to sign the order and the reissuance of the "Standby_Counsel" discovery to new counsel.

6. Stand-by 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.

7. If stand-by counsel makes, or causes to be made, any further copies of any of the "Standby_Counsel" discovery, stand-by counsel will inscribe the following notation on each copy or incorporate onto electronic files (efiles): "U.S. Government Property; May Not Be Disseminated Without U.S. Government Permission." Dashawn Williams, the defendant in pro per, will not make any further copies of "Williams_Pro_Se" discovery without the court's permission.

8. If stand-by counsel or assigned defense investigator or defense paralegal releases custody of any of the discovery, or authorized copies thereof, to any person described in paragraph three, stand-by 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.

9. Stand-by counsel shall advise government counsel of any subpoenas, document requests or claims for access to the discovery by third parties in order that the government may take action to resist or comply with such demands as it may deem appropriate.

10. Stand-by counsel shall be responsible for advising Dashawn Williams, the defendant in pro per, employees and other members of the defense team, and defense witnesses of the contents of this Stipulation/Order.

IT IS SO STIPULATED.

ORDER

The Stipulation of stand-by counsel, including the defendant in pro per, in Criminal Case No. 2:13-cr-00366-KJM is approved, and

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.