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United States v. Marcks

United States District Court, D. Nevada

January 14, 2020

UNITED STATES OF AMERICA, Plaintiff,
v.
GINA MARCKS, a/k/a "Gina Toscano," a/k/a "Gina Melwani," a/k/a "Gina Marewani," LADDA BOONLERT, CHARLES HILL, WENDI A. MARYNIAK, ROGER BOND, a/k/a "Charles Roger Bond," Defendants.

          NICHOLAS A. TRUTANICH United States Attorney

          PATRICK BURNS Assistant United States Attorney

          HEIDI OJEDA Assistant Federal Public Defender Attorney for DEFENDANT MARCKS

          MICHAEL J. MICELI, ESQ.

          Attorney for DEFENDANT BOONLERT

          CHRIS T. RASMUSSEN, ESQ. Attorney for DEFENDANT HILL

          RUSSELL MARSH, ESQ. Attorney for DEFENDANT MARYNIAK

          AMANDA S. GREGORY, ESQ. Attorney for DEFENDANT BOND

          STIPULATION FOR A PROTECTIVE ORDER

          HON. NANCY J. KOPPE UNITED STATES MAGISTRATE JUDGE

         The parties, by and through the undersigned, respectfully request that the Court issue an order protecting from disclosure to the public, or any third party not directly related to this case, any documents, recordings, or other tangible things produced by the government during discovery that contain confidential or personal identifying information of individuals referenced in the discovery. The parties state as follows:

         1. The indictment in this case issued on December 10, 2019.

         2. Trial is currently scheduled for February 25, 2020.

         3. The indictment in this case arises out of an alleged scheme to defraud involving impersonation of IRS and other government officials. The discovery contains significant amounts of alleged victim information, bank and financial account numbers and information, personal identifying information and documents such as driver's licenses, and some tax return and taxpayer information otherwise deemed confidential under 26 U.S.C. § 6103. The release of such information to the public or third parties not involved in the case could endanger the privacy of hundreds of individuals and also subject them to potential misuse of their identities. This confidential information is referred to here as the "Protected Information." 4. In order to protect the privacy of the individuals referenced in the discovery, the parties intend to restrict access to the following individuals: attorneys for all parties, and any personnel that the attorneys for all parties consider necessary to assist in performing that attorney's duties in the prosecution or defense of this case, including investigators, paralegals, retained experts, support staff, interpreters, and any other individuals specifically authorized by the Court (collectively, the "Covered Individuals").

         5. The Covered Individuals shall be advised of the Protective Order, and, without leave of Court, ...


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