PROTECTIVE ORDER

JAMES L. ROBART, District Judge.

This matter having come before the Court on a Stipulated Motion for Entry of a Discovery Protective Order, the Court hereby enters the following:

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, immigration history/status, and/or any other similar information or number implicating a privacy interest and belonging to an individual, business, partnership, or corporation.

"Protected Information" also includes the name of any victim of the charged offenses or any non-defendant witness.

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

B. Procedures

The government is not required to redact Protected Information that pertains only to the Defendant or an immediate family member of the Defendant.

Defense counsel may produce to the Defendant any documents that contain Protected Information or Protected Material that pertains only to the Defendant or an immediate family member of the Defendant. Defense counsel may also produce any document to the Defendant that that does not contain any Protected Information or Protected Material.

Items designated in the government's discovery log as "Protected" contain Protected Information and the associated files and/or documents are not to be produced to the Defendant except as described below.

Possession of all other Protected Information and/or Protected Material is hereby limited to the attorneys of record in the above captioned case and their investigators and agents. The attorneys of record and their investigators and agents may review Protected Information and/or Protected Material with the Defendant. The Defendant may visually inspect and review such documents but shall not be allowed to possess Protected Information (such as unredacted copies of Protected Material or notes, copies, or photographs of such Protected Material containing Protected Information). The Defendant may possess documents from which all Protected Information has been redacted.

The attorneys of record and their investigators and agents may review or discuss the contents of documents containing Protected Material with any prospective witness, as long as the attorneys of record and investigators and agents do not share the unredacted documents, or share any Protected Information of victims or witnesses, with any prospective witness.

If any Protected Information or Protected Material is filed in court or otherwise disseminated as part of litigation, the parties agree to 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.

For redactions, numbers that constitute Protected Information shall be redacted to the last 2-4 digits and names shall be redacted to initials, or otherwise as needed to comply with applicable federal and local rules.

The attorneys of record and their investigators and agents shall keep any Protected Material secured whenever the Protected Material is not being used in furtherance of their work in the above-captioned 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 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.