United States District Court, D. Nevada
CHARLES LA BELLA, KATHLEEN McGOVERN, Deputy Chiefs, THOMAS B. W. HALL, ALISON L. ANDERSON, Trial Attorneys, Fraud Section, Criminal Division U.S. Department of Justice, Washington, DC,
DANIEL ALBREGTS, Counsel for Defendant Benzer.
RODNEY SNOW, Counsel for Defendant Gregory.
DOUGLASS A. MITCHELL, Counsel for Defendant McChesney.
BRET WHIPPLE, MICHAEL SANFT, Counsel for Defendant Ball.
STIPULATION AND PROTECTIVE ORDER
GEORGE FOLEY, Jr., Magistrate Judge.
IT IS HEREBY STIPULATED AND AGREED between the parties, Jeffrey H. Knox, Chief, U.S. Department of Justice, Criminal Division, Fraud Section, Deputy Chief Charles La Bella, Senior Deputy Chief of Litigation, Kathleen McGovern, and Trial Attorneys Thomas B.W. Hall and Alison L. Anderson, counsel for the United States, and the following defense counsel (collectively referred to as "Defense Counsel"):
Daniel Albregts, counsel for Defendant Leon Benzer
Rodney Snow, counsel for Defendant Keith Gregory
Douglass A. Mitchell, counsel for Defendant Charles McChesney
Bret Whipple, counsel for Defendant Salvatore Ruvolo
Michael Sanft, counsel for Defendant David Ball
that this Court issue an Order protecting from disclosure to the public any discovery documents relating to sensitive material produced pursuant to this protective order. Such documents shall be referred to hereinafter as "Protected Documents." The parties state as follows:
1. This Court has the power to issue "protective and modifying orders" regulating discovery. Fed. R. Crim. P. 16(d)(1). Specifically, "[a]t any time the court may, for good cause, deny, restrict, or defer discovery or inspection, or grant other appropriate relief." Id. ; see also Alderman v. United States, 394 U.S. 165, 185 (1969) ("The trial court can and should, where appropriate, place a ...