Protective Order for Discovery Materials 7 Motion — USA v. Slaton (Dkt. 8, N.D. Ga.)

Record facts

U.S. District Court for the Northern District of Georgia · No. 1:21-cr-00179-JPB · Doc. 8 · 2021-05-17 · Docket on CourtListener

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FILED IN OPEN COURT
U.S.D.C. - Atlanta
MAY 172021
IN THE UNITED STATES DISTRICT COURT
J~1ES N. HAHEN, Clerk
FOR THE NORTHERN DISTRICT OF GEORGIA
By.
~P’~eputy Clerk
ATLANTA DIVISION
UNITED STATES OF AMERICA
v.
Case No. 1:21-CR-179
DENESSERIA SLATON A/K/A
DENESSERIE SLAT0N
Protective Order for Discovery Materials
WHEREAS the discovery materials provided and otherwise made available to
the defendant by the United States in this case are voluminous, contain
confidential and sensitive personal information pertaining to individuals who
are not parties to this litigation, such as dates of birth, addresses, social security
numbers, and bank account numbers; and
WHEREAS redaction of all potential confidential and sensitive information in
this voluminous production would be unduly burdensome, and would be
subject to error given the volume of documentation involved in this production;
THEREFORE, IT IS HEREBY ORDERED, pursuant to Rule 16(d) of the
Federal Rules of Criminal Procedure, that:
1. Any and all materials and information provided by the United States to
the defendant (hereinafter referred to in this Order as “discovery”) are to be used
by the defendant and her counsel solely for the purpose of allowing the
defendant to prepare her defense, and the defendant, defense counsel, and/or
members of the defense team will not disseminate, disclose, or provide discovery
materials containing the confidential and sensitive information identified herein
to anyone who is not necessary to the preparation of the defense.
Case 1:21-cr-00179-JPB     Document 8     Filed 05/17/21     Page 1 of 3

2. All discovery materials provided by the United States, regardless of
whether such materials and information have already been produced or will be
produced in the future, and regardless of whether such materials and
information have or will be produced pursuant to Rule 16 or otherwise, shall not
be further disseminated by the defendant or her counsel to any individual,
organization, or other entity, other than: (1) members of the defense team (i.e.,
co-counsel, paralegals, investigators, litigation support personnel, the defendant,
and secretarial staff); (2) any experts or consultants retained to assist in the
preparation of the defense; and (3) the Court, unless the confidential and
sensitive information identified herein is redacted from such materials and
information. Upon any dissemination of the materials and information
containing the confidential and sensitive information identified herein, defense
counsel will inform the recipient of this Protective Order and the requirement to
maintain the confidentiality of the information conveyed.
3. Defense counsel, any co-counsel, and any investigators may show copies
of any discovery containing the confidential and sensitive information identified
herein to non-expert witnesses if it is determined that it is necessary to do so for
the purpose of preparing the defense of the case, and may do so without any
notice to the United States. Defense counsel may also provide copies of
discovery documents to witnesses in advance of meeting with them, so long as
the witnesses agree that they will not disseminate the documents and defense
counsel retrieves all copies of the documents from the witnesses subsequent to
meeting with them.
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Case 1:21-cr-00179-JPB     Document 8     Filed 05/17/21     Page 2 of 3

4. If the defendant’s counsel desire to disclose any discovery or make
available or communicate the content of such discovery containing the
confidential and sensitive information identified herein to any other person not
described in this Order, Government’s counsel must first be so advised and seek
to reach an informal resolution of or agreement on the matter. If an agreement
cannot be reached, the defendant’s counsel shall apply to the Court for relief
from this Order.
5. If the defendant’s counsel desire to file any discovery as attachments to
motions and it appears that the discovery contains information subject to this
Order, the discovery must be filed under seal so as not to reveal sensitive
information on the public docket.
6. This ORDER solely governs the defendant’s and defense team’s use of
documents produced in this action from the United States. This ORDER does not
limit the defendant’s and defense team’s use of documents that they might
already possess prior to receiving discovery, or might obtain through other
means.
7. This ORDER shall survive the final termination of this action and, upon
termination of this action and any appeal, counsel for the defendant shall return
all copies of the discovery to the Government, or shall certify that said
documents have been destroyed.
SO ORDERED this 17th day of ~
JOH~ K.
ARKINS III
UNITED STATES MAGISTRATE JUDGE
Prepared by:
Tal C. Chaiken, Assistant United States Attorney
(404) 581-6069
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