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United States v. Castro

United States District Court, D. Nevada

December 26, 2019

UNITED STATES OF AMERICA, Plaintiff,
v.
MARIO CASTRO, JOSE SALUD CASTRO, SALVADOR CASTRO, MIGUEL CASTRO JOSE LUIS MENDEZ, AND ANDREA BURROW, Defendants.

          NICHOLAS A. TRUTANICH United States Attorney TIMOTHY FINLEY DANIEL ZYTNICK Trial Attorneys U.S. Department of Justice Consumer Protection Branch

          ERICK M. FERRAN Counsel for Defendant MARIO CASTRO

          OSVALDO E. FUMO Counsel for Defendant JOSE SALUD CASTRO

          DONALD J. GREEN Counsel for Defendant SALVADOR CASTRO

          YI LIN ZHENG Counsel for Defendant MIGUEL CASTRO

          TELIA U. WILLIAMS Counsel for Defendant JOSE LUIS MENDEZ

          CRANE M. POMERANTZ Counsel for Defendant ANDREA BURROW

          PROTECTIVE ORDER

          NANCY J. KOPPE, UNITED STATES MAGISTRATE JUDGE.

         The United States, by and through its counsel of record, and defendants Mario Castro, Jose Salud Castro, Salvador Castro, Miguel Castro, Jose Luis Mendez, and Andrea Burrow, by and through their undersigned counsel (collectively, hereinafter "the parties"), respectfully move for entry of a Protective Order governing discovery provided to the defendants 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 or that are otherwise sensitive.

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

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


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