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United States v. Suzuki

United States District Court, D. Nevada

May 20, 2019

UNITED STATES OF AMERICA, Plaintiff,
v.
JUNZO SUZUKI, and PAUL SUZUKI, Defendants.

          ROBERT ZINK, Acting Chief, Fraud Section, Criminal Division United States Department of Justice.

          WILLIAM JOHNSTON, DANNY NGUYEN, Trial Attorneys Criminal Division, Fraud Section.

          NICHOLAS TRUTANICH United States Attorney District of Nevada.

          RICHARD ANTHONY LOPEZ Date Assistant United States Attorney District of Nevada.

          RICHARD A. WRIGHT Date Counsel for Defendants JUNZO SUZUKI and PAUL SUZUKI

          STIPULATION AND PROTECTIVE ORDER

          NANCY J. KOPPE UNITED STATES MAGISTRATE JUDGE.

         The United States of America, through Robert Zink, Acting Chief of the Criminal Division's Fraud Section, William E. Johnston and Danny Nguyen, Trial Attorneys, Nicholas A. Trutanich, United States Attorney, and Richard Anthony Lopez, Assistant United States Attorney, counsel for the United States, and defendants Junzo SUZUKI, and Paul SUZUKI, by and through their undersigned counsel, respectfully move for the entry of a Protective Order governing discovery in this matter in accord with the following Stipulation.

         STIPULATION

         Whereas, the parties recognize that various federal and state laws and regulations extend protections and limitations regarding the use, disclosure or publication of information associated with the privacy and identity of an individual, including, but not limited to, social security number, date of birth, address, telephone number, driver's license number, financial information, banking information, and tax information, which is hereinafter collectively referred to as "Protected Personal Information" ("PPI").

         Whereas, the parties recognize that discovery in the above-captioned case is likely to be voluminous and may include documents and other evidence containing PPI of the defendants and/or third parties.

         Whereas, the parties desire to provide for the timely and expeditious exchange of discovery while simultaneous guarding against the inappropriate use, disclosure, or publication of any PPI associated with any party or third party.

         Whereas, in light of the above, the parties have conferred on this matter and have reached agreement on the exchange and handling of PPI.

         IT IS HEREBY STIPULATED AND AGREED by and between the undersigned parties, as follows:

         1. Documents containing PPI will be referred to as "Protected Documents." 2. The government may produce Protected Documents to the defendant ...


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