STIPULATION AND PROTECTIVE ORDER

JENNIFER L. THURSTON, Magistrate Judge.

STIPULATION REGARDING DISCOVERY AND PROTECTIVE ORDER

The United States of America, by and through MCGREGOR W. SCOTT, United States Attorney, and Melanie L. Alsworth, Assistant United States Attorney, and the defendants, through their respective counsel of record, hereby stipulate 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 Order pertains to all recordings and statements of witnesses provided to or made available to Defense Counsel as part of discovery in this case or to comply with trial obligations pursuant to Title 18, United States Code, Section 3500 (the Jenck's Act), or to comply with Brady and Giglio obligations.

3. By signing this Stipulation and Protective Order, Defense Counsel agrees not to share any recordings, documents or statements of witnesses with anyone other than designated defense investigators and support staff. Defense Counsel may review the contents of recordings and documents with the defendants, and the parties agree that Defense Counsel, defense investigators and support staff shall not allow the defendants to copy such information.

4. By signing this Stipulation and Protective Order, Defense Counsel agrees not to disclose the identity of any witness to anyone other than those individuals identified in Paragraph 3. Defense counsel agrees that he or she will not provide the defendants with any documentation identifying the witnesses. Defense Counsel agrees to admonish Defendants not to disclose the identities of any witnesses.

5. The discovery and information provided by the Government 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. Defense Counsel will return the discovery to the Government or certify that it has been shredded at the conclusion of the case.

6. 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.

7. Defense Counsel shall be responsible for advising his or her respective defendant, employees, and other members of the defense team, and defense witnesses of the contents of this Stipulation/Order.

8. In the event that the 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.