STIPULATION AND [PROPOSED] ORDER REGARDING PROTECTED MATERIALS PRODUCED ON OR AFTER MARCH 28, 2016

YVONNE GONZALEZ ROGERS, District Judge.

The United States, through its counsel of record ("the Government"), and defendants Henry Cervantes, Alberto Larez, Jaime Cervantes, and Andrew Cervantes, by and through their counsel of record, hereby agree and stipulate that the Government has and will continue to provide discovery on the following conditions set forth below pursuant to its disclosure obligations. The reason for this stipulation is that some of the discovery in this case contains sensitive information, including names of cooperating witnesses and percipient witnesses whose safety may be at risk should their identities be disclosed. The Government is producing material currently in its possession pursuant to this Protective Order, including Jencks material, Giglio material, and other sensitive documents, hereinafter "Protected Material." Possession of the Protected Material is limited to the attorney of record, and investigators, paralegals, law clerks, translators, interpreters, experts and assistants for the attorneys of record (hereinafter collectively referred to as "members of the defense team").

The members of the defense team acknowledge that providing copies of the Protected Material to other persons is prohibited, and agree not to duplicate or provide copies of the Protected Material to other persons. The members of the defense team further acknowledge that they are prohibited from using the Protected Material for any purpose other than defending the defendants in the above-captioned matter. The defense team may not disseminate or show the Protected Materials to the defendants, but they are not barred from discussing the matters described in the Protected Materials with the defendants to the extent necessary to prepare a defense. Any violation of these prohibitions constitutes a violation of the Protective Order. Further, the attorneys of record agree that prior to disseminating any copies of the Protected Material to members of the defense team, they will provide a copy of this Protective Order to members of the defense team.

Members of the defense team further acknowledge that should the case against their client resolve in advance of trial, that members of the defense team agree to return copies of the Protected Material to the government, or otherwise destroy all copies of the Protected Material which remain in their possession.

Each individual member of the defense team shall sign a copy of this Protective Order to acknowledge their understanding of it and counsel for whom the individual works shall provide a copy of the signed Protective Order to the Government.

IT IS SO STIPULATED.

PROPOSED ORDER

The Court finds appropriate the parties' stipulation with respect to the provision of the Protected Material in this case. Accordingly, it is hereby ORDERED that discovery will be produced and handled in accordance with the terms outlined in the "Stipulation Regarding Provision of Protected Materials."

IT IS SO ORDERED.