Opinion
Case No. 2:11-cr-00353-MCE
09-06-2011
UNITED STATES OF AMERICA, Plaintiff, v. SEAN McCLENDON, ANTHONY SALCEDO, ANTHONY WILLIAMS, Defendants.
Respectfully submitted, BENJAMIN B. WAGNER United States Attorney By: JEAN M. HOBLER Assistant U.S. Attorney DANIEL BRODERICK FEDERAL DEFENDAER By: DOUGLAS BEEVERS Assistant Federal Defender Counsel for ANTHONY SALCEDO
BENJAMIN B. WAGNER
United States Attorney
JEAN M. HOBLER
Assistant U.S. Attorneys
STIPULATION AND PROTECTIVE ORDER - RE: DEFENDANT SALCEDO
WHEREAS, the parties desire to prevent the unauthorized disclosure or dissemination of certain sensitive but unclassified discovery materials to anyone not a party to the court proceedings in this matter;
WHEREAS, the parties agree that entry of a stipulated protective order is appropriate; and
WHEREAS, the defendant ANTHONY SALCEDO has counsel who wishes the opportunity to review the discovery,
Defendant ANTHONY SALCEDO and Plaintiff United States of America, by and through their counsel of record, hereby agree and stipulate as follows:
1. This Court may enter protective orders 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. Defense Counsel shall not disclose any of the discovery to any person other than his client, or attorneys, law clerks, paralegals, secretaries, experts, and investigators, involved in the representation of his client.
4. The discovery and information therein may only be used 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 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. If Defense Counsel releases custody of any of the discovery, or authorized copies thereof, to any person described in paragraph (3), Defense Counsel shall provide such recipients with copies of this Order and advise that person that the discovery is the property of the United States Government, that the discovery and information therein may only be used in connection with the litigation of this case and for no other purpose, and that an unauthorized use of the discovery may constitute a violation of law and/or contempt of court.
7. Defense Counsel shall be responsible for advising his client, employees, and other members of the defense team of the contents of this Stipulation/Order.
IT IS SO STIPULATED.
Respectfully submitted,
BENJAMIN B. WAGNER
United States Attorney
By: JEAN M. HOBLER
Assistant U.S. Attorney
DANIEL BRODERICK
FEDERAL DEFENDAER
By: DOUGLAS BEEVERS
Assistant Federal Defender
Counsel for ANTHONY SALCEDO
ORDER
IT IS SO FOUND AND ORDERED.
MORRISON C. ENGLAND, JR
UNITED STATES DISTRICT JUDGE