STIPULATION AND PROTECTIVE ORDER BETWEEN THE UNITED STATES OF AMERICA AND DEFENDANT ANGELICA MORENO-VELASQUEZ

LAWRENCE J. O'NEILL, Chief District Judge.

WHEREAS, the discovery in this case is expected to contain a limited amount of sensitive information that potentially may reveal confidential sources and methods ("Protected Information"); and

WHEREAS, the parties desire to avoid potentially revealing confidential sources and methods;

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

Therefore, Defendant ANGELICA MORENO-VELASQUEZ, by and through her counsel of record ("Defense Counsel"), and the United States of America, by and through Assistant United States Attorney Christopher D. Baker, hereby agree and stipulate as follows:

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

2. This Order pertains only to discovery provided to or made available to Defense Counsel in this case subsequent to the date of entry of this Order and which is marked with a "Confidential" bates stamp marking (hereafter, collectively known as the "discovery").

3. By signing this Stipulation and Protective Order, Defense Counsel agrees not to share any documents that contain Protected Information with anyone other than Defense Counsel attorneys, designated defense investigators, and support staff. Defense Counsel may permit the Defendant to view unredacted documents in the presence of her attorney, defense investigators, and support staff. The parties agree that Defense Counsel, defense investigators, and support staff shall not allow the Defendant to copy Protected Information contained in the discovery.

4. The discovery and information therein may be used only 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 of America ("Government"). Defense Counsel will return the discovery to the Government or certify that it has been destroyed 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. Defense Counsel shall be responsible for advising the Defendant, employees, and other members of the defense team, and defense witnesses of the contents of this Stipulation and Order.

7. In the event that Defendant substitutes counsel, undersigned Defense Counsel 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 ORDERED.