STIPULATION REGARDING PROTECTIVE ORDER AND ORDER FOR TRANSFER OF DISCOVERY TO NEW COUNSEL

ANTHONY W. ISHII, Senior District Judge.

STIPULATION

The parties to this action, by and through their respective counsel, stipulate and agree as follows:

1. Electronic surveillance was conducted in connection with the investigation in the above-entitled case. Accordingly, numerous documents were filed with the Court under seal relating to the electronic surveillance. The government has met its discovery obligations to the defendant, Keith Foster, through his former counsel, E. Marshall Hodgkins, III, with regard to such documents filed with the Court and the communications intercepted.

2. On June 2, 2017, Michael G. McKneely was substituted as the attorney for Keith Foster. Defendant's former attorney should transfer all of the discovery in this matter to Michael G. McKneely as soon as practicable following modification of the prior order prohibiting disclosure.

3. Persons who have not been charged in any criminal conduct, but who were identified in the documents filed with the Court regarding the electronic surveillance and/or whose communications were intercepted, have privacy interests. Disclosure of the discovery by the government implicated the privacy interests of these persons.

4. Therefore, the parties and their respective counsel, including staff, investigators, and outside assistants, shall not disclose the contents of the documents released by the government in discovery, except as necessary for investigation or presentation in Court proceedings in the above-entitled case.

5. The documents filed with the Court in connection with the electronic surveillance in the above-entitled case shall remain sealed from the general public.

ORDER

Pursuant to the stipulation of the parties set forth above, IT IS HEREBY ORDERED:

1. E. Marshall Hodgkins, III, may provide to Michael G. McKneely all of the discovery received from the government in this case, including the Court documents filed under seal in connection with the electronic surveillance conducted in the investigation of the above-entitled case and the communications intercepted.

2. The parties and their respective counsel, including staff, investigators, and outside assistants, shall not disclose the contents of the documents released by the government in discovery, except as necessary for investigation or presentation in Court proceedings in the above-entitled case.

3. The documents filed with the Court in connection with the electronic surveillance in the above-entitled case shall remain sealed from the general public.

IT IS SO ORDERED.