Opinion
CASE NO.: l:ll-cr-00274-LJO
10-04-2011
UNITED STATES OF AMERICA, Plaintiff, v. ALFONSO CASAREZ, ROSEMARY FIERROS, VICTOR VASQUEZ, ANGEL OCIRIS GUTIERREZ, ALCIDES URIAS, DIMAS DOMINGUEZ MARTINEZ, JESUS DOMINGUEZ MARTINEZ, LUIS ALBERTO MORENO DELGADO, ARMANDO TREYES ANDRADE, ARMANDO SOLORIO HEREDIA, JOSE MANUEL GARCIA, ARMANDO MARAVILLA, and CASSANDRA CASAREZ FIERROS, Defendants.
BENJAMIN B. WAGNER United States Attorney HENRY Z. CARBAJAL III Assistant U.S. Attorney MARC DAYS Attorney for Defendant ALFONSO CASAREZ JAMES R. HOMOLA Attorney for Defendant ROSEMARY FIERROS MARTIN TALEISNIK Attorney for Defendant VICTOR VASQUEZ DANIEL A. BACON Attorney for Defendant ANGEL OCIRIS GUTIERREZ DAVID J. COHEN Attorney for Defendant ALCIDES URIAS JULIUS M. CRUZ Attorney for Defendant DIMAS DOMINGUEZ MARTINEZ DALE A. BLICKENSTAFF Attorney for Defendant JESUS DOMINGUEZ MARTINEZ TINA M. BARBERI Attorney for Defendant JOSE MANUEL GARCIA GARY L. HUSS Attorney for Defendant LUIS ALBERTO MORENO DELGADO PETER M. JONES Attorney for Defendant ARMANDO TREYES ANDRADE DAVID E. JONES Attorney for Defendant ARMANDO SOLORIO HEREDIA BARBARA H. O'NEILL Attorney for Defendant ARMANDO MARAVILLA ERIC K. FOGDERUDE Attorney for Defendant CASSANDRA CASAREZ FIERROS
BENJAMIN B. WAGNER
United States Attorney
HENRY Z. CARBAJAL III
GRANT B. RABENN
Assistant U.S. Attorneys
Attorneys for the
United States of America
STIPULATION AND PROTECTIVE
ORDER BETWEEN THE UNITED
STATES AND DEFENDANTS
WHEREAS, the discovery in this case is voluminous and contains a large amount of personal and confidential information including but not limited to Social Security numbers, dates of birth, bank account numbers, telephone numbers, and residential addresses ("Protected Information"); and
WHEREAS, the parties desire to avoid both the necessity of large scale redactions and the unauthorized disclosure or dissemination of this information to anyone not a party to the court proceedings in this matter;
The parties agree that entry of a stipulated protective order is appropriate.
THEREFORE, Defendants, by and through their counsel of record ("Defense Counsel"), and the United States of America, by and through Assistant United States Attorney Henry Z. Carbajal III, hereby agree and stipulate as follows:
1. This Court may enter a protective order pursuant to Rule 16(d) of the Federal Rules of Criminal Procedure, and its general supervisory authority.
2. This Order pertains to all discovery provided to or made available to Defense Counsel as part of discovery in this case (hereafter, collectively known as "the discovery").
3. By signing this Stipulation and Protective Order, Defense Counsel agrees not to share any documents that contain Protected Information with anyone other than Defense Counsel attorneys, designated defense investigators, and support staff. Defense Counsel may permit the Defendant to view unredacted documents in the presence of his attorney, defense investigators, and support staff. The parties agree that Defense Counsel, defense investigators, and support staff shall not allow the Defendant to copy Protected Information contained in the discovery. The parties agree that Defense Counsel, defense investigators, and support staff may provide the Defendant with copies of documents from which Protected Information has been redacted.
4. The discovery and information therein may be used only in connection with the litigation of this case and for no other purpose. The discovery is now and will forever remain the property of the United States of America ("Government"). Defense Counsel will return the discovery to the Government or certify that it has been shredded at the conclusion of the case.
5. Defense Counsel will store the discovery in a secure place and will use reasonable care to ensure that it is not disclosed to third persons in violation of this agreement.
6. Defense Counsel shall be responsible for advising his Defendant, employees, and other members of the defense team, and defense witnesses of the contents of this Stipulation and Order.
7. In the event that Defendant substitutes counsel, undersigned Defense Counsel agrees to withhold discovery from new counsel unless and until substituted counsel agrees also to be bound by this Order.
IT IS SO STIPULATED.
BENJAMIN B. WAGNER
United States Attorney
HENRY Z. CARBAJAL III
Assistant U.S. Attorney
MARC DAYS
Attorney for Defendant
ALFONSO CASAREZ
JAMES R. HOMOLA
Attorney for Defendant
ROSEMARY FIERROS
MARTIN TALEISNIK
Attorney for Defendant
VICTOR VASQUEZ
DANIEL A. BACON
Attorney for Defendant
ANGEL OCIRIS GUTIERREZ
DAVID J. COHEN
Attorney for Defendant
ALCIDES URIAS
JULIUS M. CRUZ
Attorney for Defendant
DIMAS DOMINGUEZ MARTINEZ
DALE A. BLICKENSTAFF
Attorney for Defendant
JESUS DOMINGUEZ MARTINEZ
TINA M. BARBERI
Attorney for Defendant
JOSE MANUEL GARCIA
GARY L. HUSS
Attorney for Defendant
LUIS ALBERTO MORENO DELGADO
PETER M. JONES
Attorney for Defendant
ARMANDO TREYES ANDRADE
DAVID E. JONES
Attorney for Defendant
ARMANDO SOLORIO HEREDIA
BARBARA H. O'NEILL
Attorney for Defendant
ARMANDO MARAVILLA
ERIC K. FOGDERUDE
Attorney for Defendant
CASSANDRA CASAREZ FIERROS
IT IS SO ORDERED.
Lawrence J. O'Neill
UNITED STATES DISTRICT JUDGE