United States v. Kemprud, 2:19-CR-00218-MCE-1. (2019)
Court: District Court, E.D. California
Number: infdco20191223968
Visitors: 3
Filed: Dec. 20, 2019
Latest Update: Dec. 20, 2019
Summary: STIPULATION AND PROTECTIVE ORDER BETWEEN THE UNITED STATES AND DEFENDANT REGARDING PRODUCTION OF PROTECTED INFORMATION DEBORAH BARNES , Magistrate Judge . WHEREAS, the discovery in this case contains personal information regarding third parties (both adults and minors), including but not limited to their names, dates of birth, physical descriptions, medical information, telephone numbers and/or residential addresses ("Protected Information"); and WHEREAS, the parties desire to avoid both t
Summary: STIPULATION AND PROTECTIVE ORDER BETWEEN THE UNITED STATES AND DEFENDANT REGARDING PRODUCTION OF PROTECTED INFORMATION DEBORAH BARNES , Magistrate Judge . WHEREAS, the discovery in this case contains personal information regarding third parties (both adults and minors), including but not limited to their names, dates of birth, physical descriptions, medical information, telephone numbers and/or residential addresses ("Protected Information"); and WHEREAS, the parties desire to avoid both th..
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STIPULATION AND PROTECTIVE ORDER BETWEEN THE UNITED STATES AND DEFENDANT REGARDING PRODUCTION OF PROTECTED INFORMATION
DEBORAH BARNES, Magistrate Judge.
WHEREAS, the discovery in this case contains personal information regarding third parties (both adults and minors), including but not limited to their names, dates of birth, physical descriptions, medical information, telephone numbers and/or residential addresses ("Protected Information"); and
WHEREAS, the parties desire to avoid both the necessity of large scale redactions and the unauthorized disclosure or dissemination of this information to anyone not a party to the court proceedings in this matter:
The parties agree that entry of a stipulated protective order is therefore appropriate.
THEREFORE, defendant EDMUND KEMPRUD, by and through his counsel of record, Douglas J. Beevers ("Defense Counsel"), and the United States of America, by and through Assistant United States Attorney Vincenza Rabenn, 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 to all discovery provided to or made available to Defense Counsel and Defendant, EDMUND KEMPRUD, as part of discovery in this case (hereafter, collectively known as "the discovery").
3. By signing this Stipulation and Protective Order, Defense Counsel and Defendant, EDMUND KEMPRUD, agrees not to share any documents that contain Protected Information with anyone other than Defendant, Defense Counsel's attorneys, designated defense investigators, designated defense experts, and support staff. Defendant may share documents with protected information with attorneys in connection with seeking representation, but agrees to retrieve such documents from such attorneys until such time as the attorney signs the protective order.
4. The discovery and information therein may be used only in connection with the litigation of this case and for no other purpose. Defendant may use the discovery in relation to medical license proceedings but may not disclose the discovery to the CA licensing authorities without approval of the U.S. Attorney or the Court. The discovery is now and will forever remain the property of the United States of America ("Government"). Defendant and Defense Counsel will return the discovery to the Government or certify that it has been shredded at the conclusion of the case, except as authorized by further order of the Court. The Federal Public Defenders shall be permitted to keep a copy of the discovery and make it available to the Defendant as required by California State Bar rules.
5. Defendant and Defense Counsel shall 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.
Dated: December 13, 2019 MCGREGOR W. SCOTT
United States Attorney
/s/ VINCENZA RABENN
VINCENZA RABENN
Assistant United States Attorney
Dated: December 13, 2019 /s/ Douglas J. Beevers
DOUGLAS J. BEEVERS
Counsel for Defendant
EDMUND KEMPRUD
IT IS SO ORDERED.
Source: Leagle
