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United States v. Garcia-Floro

United States District Court, D. Nevada

March 20, 2017

UNITED STATES OF AMERICA, Plaintiff,
v.
JULIUS STEPHEN GARCIA-FLORO, Defendant.

          STEVEN MYHRE Acting United States Attorney.

          SHANNON M. BRYANT Assistant United States Attorney.

          LAUREN D. GORMAN Assistant Federal Public Defender.

          STIPULATION FOR DISCOVERY PROTECTIVE ORDER

         The 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.

         The parties enter into this Stipulation for the following reasons:

         1. This case started with a multi-agency investigation that involved other nations including, but not limited to, the United States.

         2. The United States and foreign law enforcement agencies have ongoing operations and investigations into individuals identified in the course of the investigation.

         3. 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.

         4. Permitting the unfettered disclosure of these materials may irreparably harm the investigative efforts of law enforcement agents of the United States and other nations.

         5. A protective order will serve to prevent the unfettered disclosure of the documents and, therefore, prevent the identified irreparable harm.

         PROTECTIVE ORDER

         This 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:

         1. This 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.

         2. The 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 ...


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