STIPULATION AND PROTECTIVE ORDER

VALERIE P. COOKE, Magistrate Judge.

IT IS HEREBY STIPULATED AND AGREED between the parties, William Stellmach, Acting Chief, U.S. Department of Justice, Criminal Division, Fraud Section, Deputy Chief Charles La Bella, and Trial Attorneys Thomas B.W. Hall and Alison L. Anderson, counsel for the United States, and Mark B. Bailus, counsel for the Defendant, Stephanie Liane Markham, that this Court issue an Order protecting from disclosure to the public any discovery documents containing the personal identifying information such as social security numbers, drivers license numbers, dates of birth, bank account numbers, bank records, or addresses of participants, witnesses and victims in this case. Such documents shall be referred to hereinafter as "Protected Documents." The parties state as follows:

1. Protected Documents which will be used by the government in its case in chief include personal identifiers, including social security numbers, driver's license numbers, dates of birth, bank account numbers, bank records, and addresses of participants, witnesses, and victims in this case.

2. Discovery in this case will be voluminous. Many of these documents include personal identifiers. Redacting the personal identifiers of participants, witnesses, and victims would prevent the timely disclosure of discovery to defendants.

3. The United States agrees to provide Protected Documents without redacting the personal identifiers of participants, witnesses, and victims.

4. Access to Protected Documents will be restricted to persons authorized by the Court, namely defendants, attorneys of record and attorneys' paralegals, investigators, experts, and secretaries employed by the attorneys of record and performing on behalf of the defendants.

5. The following restrictions will be placed on defendants, defendants' attorneys and the above-designated individuals unless and until further ordered by the Court. Defendants, defendants' attorneys and the above-designated individuals shall not:

a. make copies for, or allow copies of any kind to be made by any other person of Protected Documents;

b. allow any other person to read Protected Documents; and

c. use Protected Documents for any other purpose other than preparing to defend against the charges in the Indictment or any superseding indictment arising out of this case.

6. Defendants' attorneys shall inform any person to whom disclosure may be made pursuant to this order of the existence and terms of this Court's order.

7. The requested restrictions shall not restrict the use or introduction as evidence of discovery documents containing personal identifying information such as social security numbers, driver's license numbers, dates of birth, and addresses during the trial of this matter.

8. Upon conclusion of this action, defendants' attorneys shall return to government counsel or destroy and certify to government counsel the destruction of all discovery documents containing personal identifying information such as social security numbers, drivers license numbers, dates of birth, and addresses within a reasonable time, not to exceed thirty days after the last appeal is final.