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BENJAMIN B. WAGNER
United States Attorney
MEGAN A. S. RICHARDS
Assistant United States Attorney
2500 Tulare Street, Suite 4401
Fresno, CA 93721
Telephone: (559) 497-4000
Facsimile: (559) 497-4099


Attorneys for Plaintiff
United States of America



IN THE UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA






CASE NO. 1:13-CR-00219-LJO-SKO

STIPULATION AND ORDER BETWEEN THE
UNITED STATES AND DEFENDANT MATEO
MANUEL SANTIAGO


UNITED STATES OF AMERICA,

Plaintiff,

v.

MAYRA ALEJANDRA SORIA,
MATEO MANUEL SATIAGO,
ERIC ALBERTO HERRERA,
BRISA CELESTE CASTILLO, and
ELISEE TORRES-PACHECO,


Defendants.





STIPULATION



WHEREAS, the discovery in this case is voluminous and contains a large amount of personal

information including but not limited to Social Security numbers, dates of birth, financial 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 Protected 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.

STIPULATION AND [PROPOSED]
ORDER



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THEREFORE, defendant MATEO MANUEL SANTIAGO, by and through his counsel of

record Brian C. Andritch (“Defense Counsel”), and plaintiff the United States of America, by and

through its 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

the 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 and

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 Government. Defense Counsel will return the discovery to the Government or

certify that it has been destroyed 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 the defendants, employees, other members of

the defense team, and defense witnesses of the contents of this Stipulation and Order.

7. In the event that the defendant substitutes counsel, undersigned Defense Counsel agrees to

withhold discovery from new counsel unless and until substituted counsel agrees also to be

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STIPULATION AND [PROPOSED]
ORDER



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bound by this Order or the Court modifies this Order regarding such transfer of discovery.

IT IS SO STIPULATED.

Dated: June 4, 2013



Dated: June 4, 2013







IT IS SO ORDERED.

Dated: June 4, 2013





DEAC_Signature-END:


b9ed48bb

BENJAMIN B. WAGNER
United States Attorney


/s/ Megan A. S. Richards
MEGAN A. S. RICHARDS
Assistant United States Attorney

/s/ Brian C. Andritch (authorized 6/4/13 via phone)
Counsel for Defendant
MATEO MANUEL SANTIAGO


/s/ Lawrence J. O’Neill
UNITED STATES DISTRICT JUDGE

STIPULATION AND [PROPOSED]
ORDER



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