United States District Court, D. Nevada
A. ORONOZ Counsel for Defendant Jocelyn Caprice Pineda.
T. RASMUSSEN Counsel for Defendant Alan Rodriguez.
W. MYHRE Acting United States Attorney RICHARD ANTHONY LOPEZ
Assistant United States Attorney RAQUEL LAZO Assistant
Federal Public Defender Counsel for Defendant Jason Lee
STIPULATION FOR PROTECTIVE ORDER
W. FOLEY, UNITED STATES MAGISTRATE JUDGE
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.
support of this Stipulation, the parties state and agree as
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.
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
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.
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.
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).
defendants in this case are not Authorized Persons.
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 ...