United States District Court, D. Nevada
MYHRE Acting United States Attorney.
SHANNON M. BRYANT Assistant United States Attorney.
D. GORMAN Assistant Federal Public Defender.
STIPULATION FOR DISCOVERY PROTECTIVE ORDER
United States of America, by and through its attorneys,
STEVEN MYHRE, Acting United States Attorney for the District
of Nevada, and SHANNON M. BRYANT, Assistant United States
Attorney, and JULIUS STEPHEN GARCIA-FLORO, Defendant, by and
through his counsel, LAUREN D. GORMAN, Assistant Federal
Public Defender, hereby submit this Stipulation for a
Discovery Protective Order to prevent dissemination and
disclosure of the discovery materials in this case to persons
other than Court personnel, the parties to this action and
their respective counsel.
parties enter into this Stipulation for the following
case started with a multi-agency investigation that involved
other nations including, but not limited to, the United
United States and foreign law enforcement agencies have
ongoing operations and investigations into individuals
identified in the course of the investigation.
Defense counsel seeks disclosure of documents currently in
possession of Government's counsel that pertain to the
international investigation, and Government's counsel
intends to produce said documents pursuant to her request.
Permitting the unfettered disclosure of these materials may
irreparably harm the investigative efforts of law enforcement
agents of the United States and other nations.
protective order will serve to prevent the unfettered
disclosure of the documents and, therefore, prevent the
identified irreparable harm.
matter, having come to the Court's attention on the
Stipulation for Entry of a Discovery Protective Order
submitted by the United States of America and Defendant
JULRJS STEPHEN GARCIA-FLORO, and the Court, having considered
the motion, and being fully advised in this matter, hereby
enters the following PROTECTIVE ORDER:
Protective Order governs all discovery material in any format
(written or electronic) that is produced by the government in
discovery in the above captioned case.
United States will make available copies of discovery
materials, including those filed under seal, to defense
counsel to comply with the government's discovery
obligations. Possession of copies of the discovery materials
is limited to the attorneys of record, and investigators,
paralegals, law clerks, experts and assistants for ...