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MELINDA HAAG (CABN 132612)
United States Attorney

J. DOUGLAS WILSON (DCBN 412811)
Chief, Criminal Division

ROBERT S. LEACH (CABN 196191)
Assistant United States Attorney


450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: (415) 436-7200
Fax: (415) 436-7234
[email protected]




Attorneys for Plaintiff


UNITED STATES OF AMERICA,

Plaintiff,

v.

ADOREAN BOLEANCU,

Defendant.


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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA





SAN FRANCISCO DIVISION


Case No. CR 13-0444 RS

STIPULATION AND [PROPOSED]
PROTECTIVE ORDER


The United States and the defendant in this action, through undersigned counsel, hereby stipulate

STIPULATION

and agree as follows:

1.

The United States is prepared to produce to defendant’s counsel of record in this matter

discovery containing sensitive tax, personal, and/or financial information of third parties, subject to the

following conditions.

2.

No counsel of record shall disclose any documents or information produced by the

United States to anyone except his or her client, any defense investigators or any defense staff working

on the case, and no defendant, defense investigator, or defense staff shall disclose such documents or

information to anyone, absent further order of the Court.

STIPULATION AND [PROPOSED]
PROTECTIVE ORDER, Case No. CR 13-0444 RS


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3.

The documents and information described above shall be used only to prepare and

evaluate the defense in this proceeding. Any person to whom the documents or information are

disclosed must be provided with a copy of this Stipulation and Order. The materials provided to defense

counsel pursuant to this Stipulation and Order, and any copies thereof, shall be returned to the

government at the conclusion of this case or shall be destroyed, with defense counsel certifying

destruction. In addition, defense counsel shall be permitted to maintain in his electronic client file one

copy of the confidential records for a period of seven years consistent with his obligations as an attorney

licensed in California. This Stipulation and Order shall be appended as the first page of that electronic

file which shall be segregated and noted as a CONFIDENTIAL FILE: SUBJECT TO PROTECTIVE

ORDER.

4.

The documents described above shall not be copied unless copying is necessary for

preparation of the defense in this proceeding. Any copy of the materials that is made shall be

accompanied at all times by a copy of this Stipulation and Order

DATED: July 29, 2013
































































































Respectfully submitted,

MELINDA HAAG
United States Attorney


__________________________
ROBERT S. LEACH
Assistant United States Attorney

/s/















/s/

COLEMAN & BALOGH LLP



__________________________
ETHAN A. BALOGH
Attorney for Defendant Adorean Boleancu












STIPULATION AND [PROPOSED]
PROTECTIVE ORDER, Case No. CR 13-0444 RS

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ORDER



In light of the stipulation and agreement of the parties to this action, and good cause appearing

therefor, it is HEREBY ORDERED that disclosure of the above-described information shall be

restricted as set for in Paragraphs 1 through 4 above.

Dated: _____________________
































___________________________________
Hon. Richard Seeborg

United States District Judge







STIPULATION AND [PROPOSED]
PROTECTIVE ORDER, Case No. CR 13-0444 RS

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7/30/13