United States District Court, D. Nevada
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
J. KOPPE UNITED STATES MAGISTRATE JUDGE.
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.
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").
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
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.
in light of the above, the parties have conferred on this
matter and have reached agreement on the exchange and
handling of PPI.
IS HEREBY STIPULATED AND AGREED by and between the
undersigned parties, as follows:
Documents containing PPI will be referred to as
"Protected Documents." 2. The government may
produce Protected Documents to the defendant ...