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United States v. Reyes-Castillo

United States District Court, D. Nevada

September 24, 2019

United States of America, Plaintiff,
v.
Jose Luis Reynaldo Reyes-Castillo, et al., Defendants.

          NICHOLAS A. TRUTANICH United States Attorney District of Nevada Nevada Bar Number 13644 SHAHEEN P. TORGOLEY Assistant United States Attorney, DAVID L. JAFFE Chief, Organized Crime & Gang Section U.S. Department of Justice JOHN S. HAN JEREMY FRANKER CHRISTOPHER TAYLOR Trial Attorneys, Representing the United States of America

          RICHARD A. WRIGHT, ESQ. JOHN BALAZS, ESQ. Counsel for defendant JOSE LUIS REYES-CASTILLO MICHAEL J.

          MICELI, ESQ. AMY E. JACKS, ESQ. Counsel for defendant MIGUEL TORRES-ESCOBAR

          ANDREA L. LUEM, ESQ. MICHAEL KENNEDY, ESQ. Counsel for defendant DAVID ARTURO PEREZ-MANCHAME

          MOTION FOR A PROTECTIVE ORDER GOVERNING DISCOVERY

          CAM FERENBACH UNITED STATES MAGISTRATE JUDGE

         The Government and the indicted Defendants in the above-captioned case, by and through their respective attorneys of record, respectfully move the Court to find that an order governing disclosure of certain discovery material is necessary pursuant to Fed. R. Crim. P. 16(d). The same parties further respectfully request that the Court find that grand jury and other discovery materials provided by the Government are being provided for the purpose of the trial in this case.

         IT IS THEREFORE ORDERED that:

         1. In order to protect the safety and privacy interests of innocent third parties and potential witnesses, to protect law enforcement interests, and to encourage early, broad and expansive discovery in this case, the defendants, the defendants' attorneys of record, and their respective staff members and others retained to work on the case:

         a) shall not distribute law enforcement reports, transcripts, recordings, and/or other materials provided by the Government pursuant to discovery except as set forth below;

         b) shall not provide any law enforcement reports, transcripts, recordings, and other materials provided pursuant to discovery to anyone with the exception of the defendants, defendant's attorneys of record in this case, members of their staff, and paralegals, law clerks, defense investigators, mitigation specialists, and experts retained by counsel to work on the case. Counsel for the defendants are ordered to provide a copy of this Order to anyone within the employ of counsel who receives such documents. Nothing in this Order prevents counsel of record for the defendants or members of their staff from showing or orally summarizing the Government discovery materials and transcripts if, in the sole discretion of counsel of record, he or she determines that it is necessary to do so for purposes of preparing the defense. Counsel of record or members of the defense team may also show and/or play audio and/or video recordings (but not provide copies of such) provided in discovery to witnesses or potential witnesses or others working at the direction of counsel of record or the defense team, if, in the sole discretion of the counsel of record, she or he determines that it is necessary to do so for purposes of preparing the defense of the case;

         c) shall not reproduce in any part, in their entirety, nor in any format, any law enforcement reports, transcripts, recordings, and/or other discovery materials for dissemination to any persons or parties, including the defendants, and shall maintain complete custody and control over the law enforcement reports, transcripts, recordings, and documents, including notes and/or copies;

         d) shall not under any circumstances allow transcripts or other discovery materials containing Jencks Act (18 U.S.C. § 3500) statements of witnesses, e.g., grand jury transcripts, Rule 11 memoranda of cooperating witnesses, witness statements whether electronically recorded or in the form of handwritten statements by the witnesses, or reports of witness statements by law enforcement officers, search warrant affidavits, or copies or summaries of the same, to remain with any defendant or to be left in any detention facility for review outside the presence of the defendant's attorney of record, or a member of the attorneys' staff;

         e) shall not provide copies of any notes or records of any kind made in relation to the contents of the discovery materials, other than to the defendant, defendant's counsel, members of their staff, and those retained to work on the case, and all such notes or records are to be treated in the manner as the original discovery materials; and

         f) shall upon conclusion of this case, including any appeal, habeas action, or other legal proceeding, dispose of all discovery materials in one of two ways, unless otherwise ordered by the Court: materials must be (1) destroyed or (2) returned to the United States. ...


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