Stipulation for Protective Order — United States v. Kerwin Aldric Jordan (C.D. Cal.)

Record facts

U.S. District Court for the Central District of California · No. 2:25-cr-00801-SVW · Doc. 19 · 2025-11-19 · Docket on CourtListener

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BILAL A. ESSAYLI 
First Assistant United States Attorney 
ALEXANDER B. SCHWAB 
Assistant United States Attorney 
Acting Chief, Criminal Division 
RANEE A. KATZENSTEIN (Cal. Bar No. 187111) 
Assistant United States Attorney 
Acting Deputy Chief, Criminal Appeals Section 
1000 United States Courthouse 
312 North Spring Street 
Los Angeles, California 90012 
Telephone: (213) 894-2432 
E-mail: 
ranee.katzenstein@usdoj.gov 
 
 
 
 
 
 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
 
UNITED STATES DISTRICT COURT 
 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
 
UNITED STATES OF AMERICA, 
 
 
 
Plaintiff, 
 
 
 
v. 
 
KERWIN ALDRIC JORDAN, 
 
Defendant. 
 
 
No. 2:25-cr-801-SVW 
 
STIPULATION AND JOINT REQUEST FOR 
A PROTECTIVE ORDER REGARDING 
DISCOVERY CONTAINING PERSONAL 
IDENTIFYING INFORMATION AND 
PRIVACY ACT INFORMATION  
 
[PROPOSED ORDER FILED 
SEPARATELY]  
 
 
 
  
Plaintiff, United States of America, by and through its counsel 
of record, the First Assistant United States Attorney for the 
Central District of California and Assistant United States Attorney 
Ranee A. Katzenstein, and defendant Kerwin Aldric Jordan 
(“defendant”), by and through his counsel of record, Deputy Federal 
Public Defender Antonio Villaamil (collectively the “parties”), for 
the reasons set forth below, request that the Court enter the 
proposed protective order (the “Protective Order”) governing the use 
and dissemination of (1) personal identifying information (“PII”) of 
real persons pursuant to Federal Rule of Criminal Procedure Rule 
Case 2:25-cr-00801-SVW     Document 19     Filed 11/19/25     Page 1 of 8   Page ID #:106

 
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16(d)(1), and (2) material that may contain information within the 
scope of the Privacy Act.   
Introduction and Grounds for Protective Order 
1. 
Defendant is charged in this matter with violations of 26 
U.S.C. § 7206(2): Aiding and Assisting in the Preparation of a False 
Tax Return; and 18 U.S.C. § 1343: Wire Fraud.  Defendant is released 
on bond pending trial. 
2. 
A protective order is necessary because the government 
intends to produce to the defense materials containing third 
parties’ PII.  The government believes that disclosure of this 
information without limitation risks the privacy and security of the 
information’s legitimate owners. Because the government has an 
ongoing obligation to protect third parties’ PII, the government 
cannot produce to defendant an unredacted set of discovery 
containing this information without the Court entering the 
Protective Order.  Moreover, PII makes up a significant part of the 
discovery in this case and such information itself, in many 
instances, has evidentiary value. If the government were to attempt 
to redact all this information in strict compliance with Federal 
Rule of Criminal Procedure 49.1, the Central District of 
California’s Local Rules regarding redaction, and the Privacy Policy 
of the United States Judicial Conference, the defense would receive 
a set of discovery that would be highly confusing and difficult to 
understand, and it would be challenging for defense counsel to 
adequately evaluate the case, provide advice to defendant, or 
prepare for trial. 
3. 
An order is also necessary because the government intends 
to produce to the defense materials that may contain information 
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within the scope of the Privacy Act, 5 U.S.C. § 552a (“Privacy Act 
Information”).  To the extent that these materials contain Privacy 
Act Information, an order is necessary to authorize disclosure 
pursuant to 5 U.S.C. § 552a(b)(11). 
4. 
The purpose of the Protective Order is to (a) allow the 
government to comply with its discovery obligations while protecting 
this sensitive information from unauthorized dissemination, and 
(b) provide the defense with sufficient information to adequately 
represent defendant.   
Definitions 
5. 
The parties agree to the following definitions: 
a. 
 “PII Materials” includes any information that can be 
used to identify a person, including a name, address, date of birth, 
Social Security number, driver’s license number, telephone number, 
account number, email address, or personal identification number. 
b. 
“Confidential Information” refers to any document or 
information containing PII Materials that the government produces to 
the defense pursuant to this Protective Order and any copies 
thereof. 
c. 
“Defense Team” includes (1) defendant’s counsel of 
record (“defense counsel”); (2) other attorneys at defense counsel’s 
law firm who may be consulted regarding case strategy in this case; 
(3) defense investigators who are assisting defense counsel with 
this case; (4) retained experts or potential experts; and 
(5) paralegals, legal assistants, and other support staff to defense 
counsel who are providing assistance on this case.  The Defense Team 
does not include defendant, defendant’s family members, or any other 
associates of defendant. 
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Terms of the Protective Order 
6. 
The parties jointly request the Court enter the Protective 
Order, which will permit the government to produce Confidential 
Information in a manner that preserves the privacy and security of 
third parties.  The parties agree that the following conditions in 
the Protective Order will serve these interests:  
a. 
The government is authorized to provide defense 
counsel with Confidential Information marked with the following 
legend: “CONFIDENTIAL INFORMATION -- CONTENTS SUBJECT TO PROTECTIVE 
ORDER.”  The government may put that legend on the digital medium 
(such as DVD or hard drive) or simply label a digital folder on the 
digital medium to cover the content of that digital folder.  The 
government may also redact any PII contained in the production of 
Confidential Information. 
b. 
If defendant objects to a designation that material 
contains Confidential Information, the parties shall meet and 
confer.  If the parties cannot reach an agreement regarding 
defendant’s objection, defendant may apply to the Court to have the 
designation removed.  
c. 
Defendant and the Defense Team agree to use the 
Confidential Information solely to prepare for any pretrial motions, 
plea negotiations, trial, and sentencing hearing in this case, as 
well as any appellate and post-conviction proceedings related to 
this case. 
d. 
The Defense Team shall not permit anyone other than 
the Defense Team to have possession of Confidential Information, 
including defendant, while outside the presence of the Defense Team. 
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e. 
At no time, under no circumstance, will any 
Confidential Information be left in the possession, custody, or 
control of defendant, regardless of defendant’s custody status. 
f. 
Defendant may review PII Materials only in the 
presence of a member of the Defense Team, who shall ensure that 
defendant is never left alone with any PII Materials.  At the 
conclusion of any meeting with defendant at which defendant is 
permitted to view PII Materials, defendant must return any PII 
Materials to the Defense Team, and the member of the Defense Team 
present shall take all such materials with him or her.  Defendant 
may not take any PII Materials out of the room in which defendant is 
meeting with the Defense Team. 
g. 
Defendant may see and review Confidential Information 
as permitted by this Protective Order, but defendant may not copy, 
keep, maintain, or otherwise possess any Confidential Information in 
this case at any time.  Defendant also may not write down or record 
any data or information contained in the Confidential Information.   
h. 
The Defense Team may review Confidential Information 
with a witness or potential witness in this case, including 
defendant.  A member of the Defense Team must be present if PII 
Materials are being shown to a witness or potential witness. No 
member of the Defense Team shall permit a witness or potential 
witness to retain Confidential Information or any notes generated 
from Confidential Information. 
i. 
The Defense Team shall maintain Confidential 
Information safely and securely, and shall exercise reasonable care 
in ensuring the confidentiality of those materials by (1) not 
permitting anyone other than members of the Defense Team, defendant, 
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witnesses, and potential witnesses, as restricted above, to see 
Confidential Information; (2) not divulging to anyone other than 
members of the Defense Team, defendant, witnesses, and potential 
witnesses, the contents of Confidential Information; and (3) not 
permitting Confidential Information to be outside the Defense Team’s 
offices, homes, vehicles, or personal presence.   
j. 
To the extent that defendant, the Defense Team, 
witnesses, or potential witnesses create notes that contain, in 
whole or in part, Confidential Information, or to the extent that 
copies are made for authorized use by members of the Defense Team, 
such notes, copies, or reproductions become Confidential Information 
subject to the Protective Order and must be handled in accordance 
with the terms of the Protective Order. 
k. 
The Defense Team shall use Confidential Information 
only for the litigation of this matter and for no other purpose.  
Litigation of this matter includes any appeal filed by defendant and 
any motion filed by defendant pursuant to 28 U.S.C. § 2255.  In the 
event that a party needs to file Confidential Information with the 
Court or divulge the contents of Confidential Information in court 
filings, the filing should be made under seal.  If the Court rejects 
the request to file such information under seal, the party seeking 
to file such information publicly shall provide advance written 
notice to the other party to afford such party an opportunity to 
object or otherwise respond to such intention.  If the other party 
does not object to the proposed filing, the party seeking to file 
such information shall redact any PII Materials and make all 
reasonable attempts to limit the divulging of PII Materials.   
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l. 
The parties agree that any Confidential Information 
inadvertently produced in the course of discovery prior to entry of 
the Protective Order shall be subject to the terms of the Protective 
Order.  If Confidential Information was inadvertently produced prior 
to entry of the Protective Order without being marked “CONFIDENTIAL 
INFORMATION -- CONTENTS SUBJECT TO PROTECTIVE ORDER,” the government 
shall reproduce the material with the correct designation and notify 
defense counsel of the error.  The Defense Team shall take immediate 
steps to destroy the unmarked material, including any copies. 
m. 
Confidential Information shall not be used by the 
defendant or Defense Team, in any way, in any other matter, absent 
an order by this Court.  All materials designated subject to the 
Protective Order maintained in the Defense Team’s files shall remain 
subject to the Protective Order unless and until such order is 
modified by this Court.     
n. 
In the event that there is a substitution of counsel 
prior to when such documents must be returned, new defense counsel 
must be informed of, and agree in writing to be bound by, the 
requirements of the Protective Order before the undersigned defense 
counsel transfers any Confidential Information to the new defense 
counsel.  New defense counsel’s written agreement to be bound by the 
terms of the Protective Order must be returned to the Assistant U.S. 
Attorney assigned to the case.  New defense counsel then will become 
the Defense Team’s custodian of materials designated subject to the 
Protective Order. 
o. 
Defense counsel agrees to advise defendant and all 
members of the Defense Team of their obligations under the 
Protective Order and ensure their agreement to follow the Protective 
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Order, prior to providing defendant and members of the Defense Team 
with access to any materials subject to the Protective Order.   
p.
Defense Counsel has conferred with defendant
regarding this stipulation and the proposed order thereon, and 
defendant agrees to the terms of the proposed order. 
q.
Accordingly, the parties have agreed to request that
the Court enter a protective order in the form submitted herewith. 
IT IS SO STIPULATED. 
DATED: Nov. 12, 2025 
DATED: Nov. __, 2025 
BILAL A. ESSAYLI 
First Assistant United States 
Attorney 
ALEXANDER B. SCHWAB 
Assistant United States Attorney 
Acting Chief, Criminal Division 
____/s/_________________________ 
RANEE A. KATZENSTEIN 
Assistant United States Attorney 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA  
___________________________ 
ANTONIO VILLAAMIL 
Attorneys for Defendant  
KERWIN ALDRIC JORDAN 
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Case 2:25-cr-00801-SVW     Document 19     Filed 11/19/25     Page 8 of 8   Page ID #:113

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