STIPULATION AND [PROPOSED] PROTECTIVE ORDER

EDMUND F. BRENNAN, Magistrate Judge.

Plaintiff United States of America, by and through its attorney of record, Assistant United States Attorney Jeremy J. Kelley, defendant Manjit Kaur Rai, by and through her counsel of record, Kresta Daly, and defendant Jagdip Singh Sekhon, by and through his counsel of record, Erin Radekin, hereby stipulate as follows:

1. The government intends to provide the defendants with a copy of the immigration file of Ranbir Khera. This copy consists of approximately 300 pages, which intermittently contain personal information including, but not limited to, social security numbers, dates of birth, telephone numbers, mailing addresses, and medical information (hereinafter "Protected Information").

2. In the absence of a protective order, numerous redactions would be necessary to avoid the unauthorized disclosure or dissemination of Protected Information to individuals not party to the court proceedings in this matter. It is possible, given the nature of the evidence, that there may be Protected Information that is inadvertently omitted during the redaction process.

3. By this stipulation, the parties jointly request that the Court issue a protective order pursuant to Rule 16(d) of the Federal Rules of Criminal Procedure and the Court's general supervisory authority.

4. The Protective Order applies to all discovery containing Protected Information, including Ranbir Khera's immigration file and any additional discovery that may be forthcoming. Discovery that does not contain Protected Information is not subject to the Protective Order.

5. Defense counsel shall not give documents that contain Protected Information (or copies of such documents) to any person other than counsel's staff, investigator(s), or retained expert(s) (hereinafter "Defense Team"). The terms "staff," "investigator," and "expert" shall not be construed to describe the defendant, or other person not: (1) regularly employed by counsel, or (2) licensed as an investigator, or (3) retained as an expert. The Defense Team shall not provide to any person copies or documents unless Protected Information has been redacted.

6. The defendant may review the Protected Information and be aware of its contents, but neither defense counsel nor the Defense Team shall provide copies of Protected Information to the defendant or allow the defendant to copy documents contacting containing Protected Information. Counsel may provide the defendant with copies of documents from which Protected Information has been redacted.

7. Social security numbers, birth dates, and residential addresses made in all public filings shall be made pursuant to Federal Rule of Criminal Procedure 49.1.

8. Nothing in this stipulation will be construed to prevent defense counsel, and the Defense Team a reasonable opportunity to prepare.

9. In the event that the defendant substitutes counsel, undersigned defense counsel agrees to withhold documents containing Protected Information from new counsel unless and until substituted counsel agrees also to be bound by this order.

IT IS SO STIPULATED.

[PROPOSED] ORDER

For good cause shown, the stipulation of counsel in criminal case no. 2:06-cr-00058-JAM-EFB is approved and so ordered. Counsel are cautioned that this Stipulated Protective Order does not entitle them to file confidential information under seal; Local Rule 141 sets forth the procedures that must be followed and the standards that will be applied when a party seeks permission from the court to file material under seal.