STIPULATION REGARDING PROTECTIVE ORDER AND [proposed] ORDER THEREON

JON S. TIGAR, District Judge.

The parties stipulate as follows:

1. Defendant Paul Lamont Lee ("Defendant") was charged with 18 U.S.C. § 286 — Conspiracy to File False Claims, 18 U.S.C. § 287 — False Claims, and 18 U.S.C. § 1028(a)(7) — Identity Theft.

2. The discovery in this matter contains, among other things, the personal information of numerous individuals including their tax returns, photo identifications, bank account information, and other personal identifying information ("witness discovery").

3. The parties agree that the witness discovery will be provided subject to the following conditions:

A. Pursuant to Rule 16(d)(1) of the Federal Rules of Criminal Procedure and 28 U.S.C. § 1651, unauthorized disclosure of witness discovery material and information contained therein to non-litigants is prohibited.

B. All materials provided as witness discovery which is or was produced by the government in preparation for or in connection with any stage of the proceedings in this case, remains the property of the United States. All such materials and all copies made thereof shall be returned to the United States Attorney's Office, Tax Division unless otherwise ordered by the Court or agreed upon by the parties, at the occurrence of the last of the following:

C. Such materials provided by the United States may be utilized by the defendant solely in connection with the defense of this case and for no other purpose and in connection with no other proceeding.

D. Such materials and their contents, and any notes or other record of such materials or their contents, shall not be disclosed either directly or indirectly to any person or entity other than the Defendant, persons employed to assist in the defense or prosecution of this matter, or such other persons as to whom the Court may expressly authorize disclosure upon proper motion.

E. Such materials shall not be copied or reproduced except as necessary to provide copies of the material for use by an authorized person as described above to prepare and assist in the defense or prosecution of this matter, and all such copies and reproductions shall be treated in the same manner as the original matter. Certain documents include information private to the government's witnesses and are made available to the Defendant only as a result of the above strict guidelines.

F. Before any such disclosure to the Defendant, defendant's counsel shall personally inform the Defendant of the provisions of this order and direct him not to disclose any information contained in the government's discovery in violation of this order, and shall inform her or him that any unauthorized disclosure may be punished as contempt of court.

G. The Defendant shall be responsible for controlling and accounting for all such material, copies, notes, and other records described above, and shall be responsible for assuring full compliance by himself/herself and any person assisting in his defense with this order. Written certification of such compliance shall be made to the Court at the time discovery materials are returned to the United States.

H. The provisions above are not meant to limit use of information provided in discovery from being used in pretrial proceedings, investigation, motions and briefs, trial and other proceedings in this litigation, unless the discovery information is protected by another protective order.

WHEREFORE, in the best interests of the administration of justice and because of the importance of protecting potential witnesses and others, it is requested that a protective order as described above be entered in this case.

In accordance with the parties' stipulation regarding the protective order, IT IS SO ORDERED.