PROTECTIVE ORDER

JOHN C. COUGHENOUR, District Judge.

This matter having come before the Court on a stipulated motion for discovery protective order (Dkt. No. 85), the Court hereby GRANTS the motion and enters the following order, applicable only as to the stipulating parties:

DISCOVERY PROTECTIVE ORDER

A. Definitions

As used in this Order, the term "Protected Information" means any date of birth, Social Security number, driver's license number, bank account number, credit card number, personal identification number, address, telephone number, name and/or location of employment, criminal history record, background check, victim identity, and/or any other similar information or number implicating a privacy interest of and belonging to an individual, business, partnership, or corporation.

As used in this Order, the term "Protected Material" means any document or other record containing or reflecting Protected Information.

B. Permissible Disclosure of Protected Information and Protected Material

The United States will make available copies of the Protected Material to defense counsel to comply with the government's discovery obligations. Possession of the Protected Material is limited to defense counsel, their investigators, paralegals, assistants, law clerks, and experts ("members of the defense team").

Members of the defense team may not provide copies of the Protected Material to other persons, including defendants themselves. Members of the defense team may review Protected Information and/or Protected Material with defendants. The defendants may visually inspect and review such documents but shall not be allowed to possess Protected Information (such as unredacted copies of Protected Material, notes, copies, or photographs of such Protected Material containing Protected Information). The defendants may possess documents from which all Protected Information has been redacted.

Members of the defense team may review or discuss the contents of documents containing Protected Material with any prospective witness, as long as they do not share the unredacted documents, or share any Protected Information with any prospective witness.

C. Filing

If any Protected Information or Protected Material is filed in court or otherwise disseminated as part of litigation, the parties shall redact such information prior to filing; unless, based on a party's application prior to filing, the Court finds that an unredacted filing is necessary and appropriate.

D. Maintenance

Members of the defense team shall keep any Protected Material secured whenever the Protected Material is not being used in furtherance of their work in the abovecaptioned case.

All documents containing Protected Material shall be returned to the United States, or destroyed, once all charges are resolved by dismissal or by final conviction. The provisions of this Order shall not terminate at the conclusion of this prosecution.

E. Modification

The parties agree that this Protective Order may be modified, as necessary, by filing with the Court a Stipulated Order Modifying the Protective Order, or by other order of the Court.

IT IS SO STIPULATED.

PURSUANT TO STIPULATION, IT IS SO ORDERED.