Proposed Protective Order — USA v. Qureshi (Dkt. 39.1)

Record facts

U.S. District Court for the District of Maryland · No. 1:22-cr-00330-JKB · Doc. 39-1 · 2023-12-19 · Docket on CourtListener

Full text

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UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF MARYLAND 
 
 
PROTECTIVE ORDER GOVERNING DISCLOSURE OF  
PERSONAL IDENTITY INFORMATION 
 
To expedite the flow of discovery material between the parties, facilitate the prompt 
resolution of disputes over confidentiality, adequately protect individually identifiable personal 
identity information entitled to be kept confidential, and ensure that protection is afforded only to 
material so entitled, it is, pursuant to the Court’s authority under Fed. R. Crim. P. 16(d) and with 
the consent of the parties, ORDERED: 
(1)  
Production of Personal Identity Information By The United States That May 
Be Subject To The Privacy Act, 5 U.S.C. '  552a, or to 42 U.S.C. ' 1306, or Other Privacy 
Protections.  The United States may produce certain individually identifiable personal identity 
information as identified in Rule 49.1 of the Federal Rules of Criminal Procedure to defendant, 
pursuant to defendant’s discovery requests.  The information produced may be subject to the 
provisions of the Privacy Act, 5 U.S.C. ' 552a or to the provisions of 42 U.S.C. ' 1306.  The 
United States shall produce these documents unredacted to the defendant.  Upon producing these 
documents to the defendant, the United States shall designate them as “confidential” in the manner 
set forth in paragraph 2, below.  The defendant, including defendant’s counsel and their personnel, 
UNITED STATES OF AMERICA 
 
                     v. 
 
AYAZ QURESHI, 
 
                    Defendant.  
 
 
CRIMINAL NO. RDB-22-0330 
 
 
 
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may use these documents only for purposes of the litigation, and may disclose them to non-parties 
to this litigation only as needed for the litigation, and only if the nonparty agrees in writing to be 
bound by the provisions of this Order.  The defendant shall not file these documents with or submit 
them to the Court or reproduce their contents in any court filing unless the document or filing is 
placed under seal or all information that would disclose identity information within the document 
or filing has been removed.  Within 90 days of the final conclusion of this litigation, defendant 
shall return the documents designated confidential and all copies, as well as all notes, memoranda, 
summaries, or other documents containing information from the designated confidential 
documents, to counsel for the United States, or shall destroy them and certify in writing to counsel 
for the United States that the documents have been destroyed.  If any documents designated as 
confidential were used as defense exhibits, defense counsel shall identify these documents, which 
shall be maintained with government exhibits so long as those are required to be maintained. 
(2)   
Designation of Material Subject to this Protective Order.  To designate 
“confidential” material covered by this Protective Order, the United States shall so designate, on 
the material itself, in an accompanying cover letter, on a diskette cover or label, or interrogatory 
or request for admission response, by using the following designation:  “CONFIDENTIAL 
INFORMATION—SUBJECT TO PROTECTIVE ORDER.”
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(3)   
Confidential Personal Identity Information in Open Court.  The procedures for 
use of designated confidential documents during any hearing or the trial of this matter shall be 
determined by the parties and the Court in advance of the hearing or trial.  The parties shall consider 
the following:  redacting confidential documents to remove individual identifiers, requesting the 
court to submit such documents under seal, coding the documents to substitute a numerical or other 
designation for the patient's name or other identifying information, requesting that any exhibit be 
placed under seal, introducing summary evidence where practicable which may be more easily 
redacted, and assuring that all Social Security numbers and other Personal Identity Information 
associated with individuals have been redacted in accordance with Rule 49.1 of the Federal Rules 
of Criminal Procedure and other applicable laws.  No party shall disclose designated confidential 
documents in open Court without prior consideration by the Court.  
(4)   
Filing of documents.  The Clerk shall accept for filing under seal any documents 
or filings so marked by the parties pursuant to the above paragraphs.   
(5)   
Modification Permitted.  Nothing in this Order shall prevent any party from 
seeking modification of this Protective Order or from objecting to discovery that it believes to be 
otherwise improper.  
(6)  
No Waiver.  The failure to designate any materials as provided in paragraph 2 shall 
not constitute a waiver of a party=s assertion that the materials are covered by this Protective Order. 
(7)   
No Ruling on Discoverability Nor Admissibility.  This Protective Order does not 
constitute a ruling on the question of whether any particular material is properly discoverable or 
admissible and does not constitute any ruling on any potential objection to the discoverability of 
any material. 
(8) 
Addition of Defendants after Entry of Order.  This Protective Order will cover 
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additional defendants in this case so long as they agree to be bound by the terms of this Protective 
Order and so indicate that consent by the execution of a supplemental stipulation, which shall be 
filed as an addendum or supplement to this Protective Order.  
 
SO ORDERED this _____ day of December, 2023. 
 
___________________________________ 
Honorable Richard D. Bennett 
United States District Judge 
 
 
 
 
  
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