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United States v. Bondarenko

United States District Court, D. Nevada

May 3, 2018

United States of America, Plaintiff,
v.
Svyatoslav Bondarenko, et al., Defendants.

          DAYLE ELIESON United States Attorney

          CHAD W. MCHENRY Assistant United States Attorney

          KELLY PEARSON Trial Attorney

          LANCE MANINGO, ESQ. Counsel for Sergey Medvedev

          MAYSOUN FLETCHER, ESQ. Counsel for Frederick Thomas

          ALAN EISNER, ESQ. Counsel for Valerian Chiochiu

          CRANE POMERANTZ, ESQ. Counsel for John Telusma

          THOMAS ERICSSON, ESQ. Counsel for Jose Gamboa

          TODD SPODEK, ESQ. Counsel for Pius Wilson

          BRIAN PUGH, AFPD Counsel for David Vargas

          STIPULATION FOR TEMPORARY PROTECTIVE ORDER

          Hon. Peggy A. Leen, United States Magistrate Judge District of Nevada.

         It is stipulated and agreed between the parties, DAYLE ELIESON, United States Attorney for the District of Nevada, CHAD W. MCHENRY, Assistant United States Attorney, and KELLY PEARSON, Trial Attorney, for the Plaintiff; and Defendants SERGEY MEDVEDEV and his counsel, LANCE MANINGO, ESQ.; FREDERICK THOMAS and his counsel, MAYSOUN FLETCHER, ESQ.; VALERIAN CHIOCHIU and his counsel, ALAN EISNER, ESQ.; JOHN TELUSMA and his counsel, CRANE POMERANTZ, ESQ.; JOSE GAMBOA and his counsel, THOMAS ERICSSON, ESQ.; PIUS WILSON and his counsel, TODD SPODEK, ESQ.; and DAVID VARGAS and his counsel, BRIAN PUGH, Assistant Federal Public Defender, that this Court issue a temporary Order protecting from disclosure to the public any data within the Government's discovery containing personally-identifying information (“PII”) or other sensitive financial data, including, but not limited to, the Social Security numbers, driver's license numbers, dates of birth, addresses, and financial account No. and logins, of participants, witnesses and victims in this case. Such documents shall be referred to as the “Protected Data.” The parties jointly request that this Court issue a temporary Order placing certain restrictions on the use of the remainder of the discovery that does not constitute “Protected Data” under these terms (the “Discovery”). Finally, the parties jointly request that the Court exempt from its temporary Order any information and documents within the Discovery that are already in the public domain.

         In support of this stipulation, the parties state as follows:

1.1. The charges in this case are based in part on allegations of widespread trafficking in PII and in sensitive financial data by members of the Infraud Organization, who obtained, used, ...

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