Protective Order by Judge Stephen v. Wilson — USA v. Ayvazyan et al. (Dkt. 92, C.D. Cal.)

Summary

Filed December 11, 2020 as Document 92 in Case 2:20-cr-00579-SVW (C.D. Cal.), this Protective Order bears the heading [Alternative Relief] [Proposed] Protective Order and a signature line for Judge Stephen V. Wilson dated December 11, 2020. It provides that the government will give defense counsel unredacted copies of all discovery materials, including those with personal information. Access to and use of the unredacted materials is limited to the defendants, their counsel and defense teams, for preparing and litigating this case. Counsel may share materials with third parties only if PII and the names of cooperating witnesses are redacted, and third parties must destroy or return them after use.

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[ALTERNATIVE RELIEF] [PROPOSED] PROTECTIVE ORDER 
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UNITED STATES DISTRICT COURT 
CENTRAL DISTRICT OF CALIFORNIA  
UNITED STATES OF AMERICA, 
v. 
RICHARD AYVAZYAN,  
MARIETTA TERABELIAN, 
ARTUR AYVAZYAN, 
TAMARA DADYAN, 
Defendants. 
Case No.  20-cr-579 (SVW)  
PROTECTIVE ORDER 
Judge: Hon. Stephen V. Wilson 
Complaint Filed: October 20, 2020 
Case 2:20-cr-00579-SVW     Document 92     Filed 12/11/20     Page 1 of 3   Page ID #:513

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PROTECTIVE ORDER 
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The Court having considered the Application for an Order Granting Discovery, 
or, in the Alternative for a Protective Order and an Order Granting Discovery and any 
opposition or replies in support thereof, the Court hereby ORDERS as follows: 
1. The government will comply with its discovery obligations pursuant to the
Federal Rules of Criminal Procedure, case law, and all applicable ethical rules. 
2. The government will provide defense counsel with unredacted copies of all
discovery materials including materials containing personal information. 
3. Access to and possession of the unredacted discovery materials is limited to
the Defendants, their counsel, and other members of the defense teams; 
4. Use of the unredacted discovery materials is limited to the preparation of the
defense and litigation of this case only; 
5. Defendants, their counsel, and other members of their defense teams are
prohibited from providing the unredacted materials to third parties with the following 
exceptions 
6. With respect to unredacted discovery materials produced by the Government,
if defense counsel redacts the materials to remove Personal Identifying Information 
(“PII”) and the names of cooperating witnesses, then Defendants, their counsel, and 
other members of their defense teams may provide the redacted materials to third 
parties for the purpose of preparing their defense. PII requiring redaction is defined 
consistently with Federal Rules of Civil Procedure Rule 5.2 and Central District of 
California Local Rule 5.2-1, to include (a) the names of cooperating witnesses, (b) 
witnesses’ dates of birth, addresses, telephone numbers, and email addresses, (c) the 
full names of minors, (d) email accounts, passwords and phone numbers, (e) the FBI’s 
internal file number, (f) fingerprint documentation, (g) driver’s license/expiration 
numbers, (h) rap-sheet Universal Control Numbers, and (i) bank account information 
except for the last four digits of the account number.   
7. Defense counsel may provide unredacted discovery materials to the entity or
Case 2:20-cr-00579-SVW     Document 92     Filed 12/11/20     Page 2 of 3   Page ID #:514

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PROTECTIVE ORDER 
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individual who owns or is the subject of the PII, provided that any PII related to third 
parties and/or the identity of any cooperating witnesses is redacted. 
8. Defense counsel may provide unredacted witness statements to the individual
who is the subject of the witness statement, provided that any PII related to third parties 
and/or the identity of any cooperating witnesses is redacted. 
9. Any third party who receives redacted discovery materials pursuant to
paragraphs 5-7 herein shall destroy or return to defense counsel all such discovery 
materials following their use for the preparation of a defense. 
IT IS SO ORDERED. 
___________________________ 
__________________________ 
Judge Stephen V. Wilson  
Date 
U.S. District Court Judge 
December 11, 2020
Case 2:20-cr-00579-SVW     Document 92     Filed 12/11/20     Page 3 of 3   Page ID #:515

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