STIPULATION AND PROTECTIVE ORDER REGARDING DISSEMINATION OF DISCOVERY DOCUMENTS CONTAINING PERSONAL IDENTIFIABLE INFORMATION

KENDALL J. NEWMAN, Magistrate Judge.

IT IS HEREBY STIPULATED AND AGREED among the parties and their respective counsel, Paul Hemesath, Assistant United States Attorney, on behalf of the government, Toni L. White, on behalf of defendant CHONDRA SHAW, and Kyle R. Knapp, on behalf of defendant SERGEY TKACHUK, that certain documents to be provided as discovery in this case are subject to a Protective Order.

The parties agree that certain discovery in the case contains Protected Information. The phrase "Protected Information" as used in this stipulation and order includes medical information, Social Security numbers, driver's license numbers, dates of birth, addresses, telephone numbers, e-mail addresses, and any other personal or financial identifying information. The proposed Protective Order extends to all documents provided by the government to defense counsel in this case that contain such Protected Information.

By signing this Stipulation and Protective Order, defense counsel agrees not to share any documents containing Protected Information in unredacted form with any person other than primary counsel, assisting counsel, designated defense investigators, and support staff. Defense counsel may allow their respective clients to view unredacted documents in his, investigators' and/or appropriate staff members' presence. The parties further agree that defense counsel, investigators, and support staff shall not permit defendant to copy, either in writing or by other means, Protected Information contained in the discovery. Defense counsel, investigators and support staff may provide defendant's with copies of documents from which all Protected Information has been redacted.

In the event that any defendant substitutes counsel, the undersigned attorneys agree to withhold documents containing Protected Information from new counsel until such time as substituted counsel agrees to be bound by this Protective Order.

FINDINGS AND ORDER

FOR GOOD CAUSE SHOWN, pursuant to the stipulation of counsel, any document containing Protected Information provided to defense counsel by the government as discovery shall:

1. Be shared in unredacted format only among primary counsel, assisting counsel, designated defense investigators, and support staff;

2. Be viewed by defendants in unredacted format only in the presence of his or her attorney, investigator, and/or appropriate support staff; and

3. Be provided to defendants only in a copy from which all Protected Information has been redacted.

No person shall permit defendant to copy, either in writing or by other means, Protected Information contained in the discovery. No person shall provide substitute counsel with documents containing Protected Information until such time as substitute counsel has agreed to be bound by this Protective Order.

IT IS SO ORDERED.