Opinion
Case No. 2:13-CR-00089 TLN
04-18-2013
UNITED STATES OF AMERICA, Plaintiff, v. ALEXANDER A. ROMANIOLIS, Defendants.
BENJAMIN B. WAGNER United States Attorney JEAN M. HOBLER Assistant U.S. Attorney Thomas A. Johnson Counsel for ALEXANDER ROMANIOLIS (Original signature in file of Plaintiff)
BENJAMIN B. WAGNER
United States Attorney
JEAN M. HOBLER
Assistant U.S. Attorney
JEFFREY A. SPIVAK
Special Assistant U.S. Attorney
501 I Street, Suite 10-100
Sacramento, CA 95814
Telephone: (916) 554-2700
STIPULATION AND [PROPOSED]
PROTECTIVE ORDER
IT IS HEREBY STIPULATED AND AGREED among the parties and their respective counsel, Jean M. Hobler, Assistant U.S. Attorney, representing plaintiff United States of America and Thomas A. Johnson, Esq., representing defendant Alexander Romaniolis, that the documents provided as discovery in this case to defense counsel are subject to a Protective Order.
The parties agree that discovery in this case contains "Protected Information," which is defined here as including victim and witness social security numbers, driver license numbers, dates of birth, addresses, telephone numbers, financial information, tax records, and email addresses. This Protective Order extends to all documents provided in this case, including those concerning conduct not directly charged in the indictment or superseding indictment.
By signing this Stipulation and Protective Order, defense counsel agree not to share any documents that contain Protected Information with anyone other than defense counsel and their designated defense investigators and support staff. Defense counsel may permit the defendants to view the documents in the presence of their attorney, defense investigators and support staff, so long as defense counsel, defense investigators and support staff do not allow the defendants to copy Protected Information contained in the discovery, and defense counsel, defense investigators, and support staff do not allow the defendants to retain unredacted copies of these records. In the event that the defendants substitute counsel, undersigned defense counsel agree to withhold documents containing Protected Information from new counsel unless and until substituted counsel agree also to be bound by this order.
IT IS SO STIPULATED.
Respectfully submitted,
BENJAMIN B. WAGNER
United States Attorney
By: ____________________________
JEAN M. HOBLER
Assistant U.S. Attorney
By: ____________________________
Thomas A. Johnson
Counsel for ALEXANDER ROMANIOLIS
(Original signature in file of Plaintiff)
ORDER
For good cause shown, the stipulation of counsel in criminal case no. 2:13-CR-00089 TLN concerning Protected Information is approved, and IT IS SO ORDERED.
____________________________
EDMUND F. BRENNAN
UNITED STATES MAGISTRATE JUDGE