STIPULATION FOR AUTHORIZATION TO PROVIDE SEALED PLEA AGREEMENT TO DEFENSE COUNSEL

D. LOWELL JENSEN, District Judge.

The defendant GUSTAVO COLIN LOPEZ (aka MICHAEL LOPEZ-FLORES), represented by Vicki H. Young, Esq., and the government, represented by Thomas A. Colthurst, Assistant United States Attorney, respectfully request that the Court authorize the government to provide counsel for the defendant in this matter with a copy of the plea agreement entered into between the government and Manual Villa and filed under seal on August 2, 2011. It is anticipated that Villa could be a witness in a sentencing hearing in this matter and that the defendant's counsel would be entitled to the plea agreement as Giglio material. The parties also agree that the plea agreement will remain under seal in the Clerk's office.

SO STIPULATED:

Accordingly, for good cause shown, the Court HEREBY ORDERS that a copy of the plea agreement for Manual Villa filed on August 2, 2011, may be provided to counsel for the defendant in United States V. Gustavo Colin Lopez, and United States v. Michael Lopez-Flores, subject to the following:

IT IS FURTHER ORDERED that the plea agreement shall not be disseminated or disclosed to anyone other than the named defendants or their counsel, or the staff of their counsel (secretaries, paralegals, clerical staff and attorneys employed by counsel and/or counsel's law firm and nonemployees engaged by counsel and under counsel's supervision who assist in counsel's representation of one of the named defendants), except upon the express authorization of this Court. Information obtained from the plea agreement may be discussed with third parties only to the extent necessary for the investigation and preparation of a named defendant's defense, provided that in no case shall the discussion of such information involve the disclosure to any third party of the document that is the source of the information or that the source of the information is a plea agreement or other document filed under seal.

IT IS FURTHER ORDERED that the plea agreement that is currently under seal shall remain sealed after the attorneys have been provided copies.

IT IS FURTHER ORDERED that any attorney receiving the plea agreement is not to disclose any information therein other than to prepare for trial and for the defense of his/her client.