Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

United States v. Pineda

United States District Court, D. Nevada

August 30, 2017

UNITED STATES OF AMERICA, Plaintiff,
v.
JOCELYN CAPRICE PINEDA et al., Defendants.

          JAMES A. ORONOZ Counsel for Defendant Jocelyn Caprice Pineda.

          CHRIS T. RASMUSSEN Counsel for Defendant Alan Rodriguez.

          STEVEN W. MYHRE Acting United States Attorney RICHARD ANTHONY LOPEZ Assistant United States Attorney RAQUEL LAZO Assistant Federal Public Defender Counsel for Defendant Jason Lee Roberts.

          STIPULATION FOR PROTECTIVE ORDER

          GEORGE W. FOLEY, UNITED STATES MAGISTRATE JUDGE

         IT IS HEREBY STIPULATED AND AGREED, by and between Steven W. Myhre, Acting United States Attorney, and Richard Anthony Lopez, Assistant United States Attorney, counsel for the United States of America, James A. Oronoz, counsel for Defendant Jocelyn Caprice Pineda, Chris T. Rasmussen, counsel for Defendant Alan Rodriguez, and Raquel Lazo, Assistant Federal Public Defender, counsel for Defendant Jason Lee Roberts, that this Court issue this Protective Order, which (as outlined herein) protects from disclosure to the public any discovery documents containing personal identifying information (PII) of participants, witnesses, and victims.

         In support of this Stipulation, the parties state and agree as follows:

         1. Discovery in this case contains more than 2, 000 pages of documents. PII contained in the discovery includes but is not limited to social security numbers, dates of birth, identification numbers, financial account numbers, and home addresses. Documents containing PII are hereinafter referred to as Protected Documents.

         2. Protected Documents in this case include but are not limited to: (a) both opened and unopened mail; (b) credit cards, debit cards, and other access devices as defined by 18 U.S.C. § 1029(e)(1); (c) identification documents as defined by 18 U.S.C. § 1028(d)(3); and (d) notebooks containing PII.

         3. Given the nature of the charges against the defendants and the fact that the Government will use Protected Documents in its case in chief at any trial, the defense team requires access to the Protected Documents. Because redacting all PII from the discovery would prevent the timely disclosure of discovery to the defendants, the parties agree to abide by the conditions in this Protective Order.

         4. The Government will provide non-redacted Protected Documents in a separate volume from discovery that does not contain PII. Any volumes of Protected Documents will be clearly marked as subject to this Protective Order.

         5. Access to Protected Documents will be restricted to attorneys of record and their paralegals, investigators, experts, secretaries, file clerks, law clerks, contractors, vendors, IT Department, and copy centers employed by the attorneys of record or performing work on behalf of defendants, and any person authorized by the Court (hereinafter referred to collectively as Authorized Persons).

         6. The defendants in this case are not Authorized Persons.

         7. Unless ordered by the Court, an Authorized Person shall not:

a. make copies of any Protected Document (or permit copies to be made) for any person who is ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.