Opinion
2:12-CR-0395-PMP-GWF
11-16-2012
UNITED STATES OF AMERICA, Plaintiff, v. EDWARD LIU, Defendants.
DANIEL G. BOGDEN United States Attorney KIMBERLY M. FRAYN Assistant United States Attorney R. DARREN CORNFORTH Counsel for defendant EDWARD LIU
DANIEL G. BOGDEN
United States Attorney
KIMBERLY M. FRAYN
Assistant United States Attorney
333 Las Vegas Boulevard South, Suite 5000
Las Vegas, Nevada 89101
Telephone: (702) 388-6336
Facsimile: (702) 388-5087
STIPULATION FOR PROTECTIVE ORDER
IT IS HEREBY STIPULATED AND AGREED between the parties, DANIEL G. BOGDEN, United States Attorney for the District of Nevada, and KIMBERLY M. FRAYN, Assistant United States Attorney, counsel for the United States, and R. DARREN CORNFORTH, ESQ., counsel for defendant EDWARD LIU, that this Court issue an Order protecting from disclosure to the public any discovery documents containing the personal identifying information and financial identifying information of participants, witnesses and victims in this case. Such documents shall be referred to hereinafter as "Protected Documents." The parties state as follows:
1. "Protected Documents" are any documents containing the personal identifying information and financial identifying information, such as, names, social security numbers, drivers' license numbers, dates of birth, addresses, debit card and credit card account numbers, financial lines of credit account numbers, bank account numbers, and Personal Identification Numbers (PINs), of participants, witnesses and victims in this case.
2. Protected Documents will be used by the government in its case in chief in this case.
3. Discovery in this case is voluminous and include many Protected Documents. Redacting the personal identifying information and financial identifying information of participants, witnesses, and victims would prevent the timely disclosure of discovery to defendants.
4. The United States agrees to provide Protected Documents without redacting the the personal identifying information and financial identifying information of participants, witnesses, and victims.
5 Access to Protected Documents will be restricted to persons authorized by the Court, namely defendant, attorney(s) of record and attorneys' paralegals, investigators, experts, and secretaries employed by the attorney(s) of record and performing on behalf of defendant.
6. The following restrictions will be placed on defendant, defendant's attorney(s) and the above-designated individuals, unless and until further ordered by the Court. Individuals with authorized access to Protected Documents shall not:
a. make copies for, or allow copies of any kind to be made by any other person of Protected Documents;
b. allow any other person to read Protected Documents; and
c. use Protected Documents for any other purpose other than preparing to defend against the charges in the Indictment or any further superseding indictment arising out of this case.
7. Defendant's attorney(s) shall inform any person to whom disclosure may be made pursuant to this order of the existence and terms of this Court's order.
8. The requested restrictions shall not restrict the use or introduction as evidence of discovery documents containing the personal identifying information and financial identifying information during the trial of this matter.
9. Upon conclusion of this action, defendant's attorney(s) shall return to government counsel or destroy and certify to government counsel the destruction of all discovery documents containing personal identifying information and financial identifying information within a reasonable time, not to exceed thirty days after the last appeal is final. DANIEL G. BOGDEN
United States Attorney
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KIMBERLY M. FRAYN
Assistant United States Attorney
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R. DARREN CORNFORTH
Counsel for defendant
EDWARD LIU
ORDER
IT IS SO ORDERED this 16th day of N o vemb er 2012.
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UNITED STATES MAGISTRATE JUDGE