Opinion
2:21-mj-00687-EJY
01-25-2022
UNITED STATES OF AMERICA, Plaintiff, v. DANIELLE PARTINGTON, Defendant.
For the United States: CHRISTOPHER CHIOU, Assistant United States Attorney. For the Defense: MICHAEL MICELI, ESQ. Attorney for DANIELLE PARTINGTON.
For the United States: CHRISTOPHER CHIOU, Assistant United States Attorney.
For the Defense: MICHAEL MICELI, ESQ. Attorney for DANIELLE PARTINGTON.
STIPULATION FOR A PROTECTIVE ORDER
The parties, by and through the undersigned, respectfully request that the Court issue an Order protecting from disclosure to the defendant DANIELLE PARTINGTON, the public, or any third party not directly related to this case, any and all unredacted discovery (the “Protected Material”) in this case. The parties state as follows:
1. On August 11, 2021, a two-count Criminal Complaint was filed charging Partington with Conspiracy and Distribution of a Controlled Substance (Fentanyl), and Aiding and Abetting, in violation of 21 U.S.C. §§ 841(a)(a), (b)(1)(C), 846, and 18 U.S.C. § 2. ECF No. 1.
2. The preliminary hearing is currently set for March 9, 2022.
3. The government is preparing to produce redacted discovery in excess of 1, 400 Bates-stamped items to defense counsel. Some of the Bates stamped items contain multiple files 1 and some consist of recordings and charts.
4. This case involves the decedent's surviving widow and possibly other victims. In order to protect other potential victims, witnesses, and unrelated persons involved in and revealed by the Protected Material, the parties intend to restrict access to the Protected Material in this case to the following individuals: the named defendants, attorneys for all parties, and any personnel that the attorneys for all parties consider necessary to assist in performing that attorneys' duties in the prosecution or defense of this case, including investigators, paralegals, experts, support staff, interpreters, and any other individuals specifically authorized by the Court (collectively, the “Covered Individuals”).
5. Without leave of Court, the Covered Individuals shall not:
a. make copies for, or allow copies of any kind to be made by any other person of the Protected Material in this case;
b. allow any other person to read, listen, or otherwise review the Protected Material;
c. use the Protected Material for any other purpose other than preparing to defend against or prosecute the charges in the indictment or any further superseding indictment arising out of this case; or d. attach the Protected Material to any of the pleadings, briefs, or other court filings except to the extent those pleadings, briefs, or filings are filed under seal.
6. Nothing in this stipulation is intended to restrict the parties' use or introduction of the Protected Material as evidence at trial or support in motion practice.
7. The parties shall inform any person to whom disclosure may be made pursuant to this order of the existence and terms of this Court's order. 2
8. The defense hereby stipulates to this protective order.
IT IS SO ORDERED: 3