Case 1:21-cr-00054-DAD-BAM Document 13 Filed 03/15/21 Page 1 of 3
1 PHILLIP A. TALBERT
Acting United States Attorney
2 ALEXANDRE DEMPSEY
Assistant United States Attorney
3 2500 Tulare Street, Suite 4401
Fresno, CA 93721
4 Telephone: (559) 497-4000
Facsimile: (559) 497-4099
5
Attorneys for Plaintiff
6 United States of America
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IN THE UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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10 UNITED STATES OF AMERICA, CASE NO. 1:21-CR-00054-DAD-BAM
11 Plaintiff, STIPULATION AND PROTECTIVE ORDER
BETWEEN THE UNITED STATES AND
12 v. DEFENDANT JASON VERTZ
13 JASON VERTZ, COURT: Hon. Barbara A. McAuliffe
and ALANA POWERS,
14 Defendants.
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16 WHEREAS, the discovery in this case is voluminous and contains a large amount of personal
17 and confidential information including but not limited to dates of birth, telephone numbers, driver’s
18 license numbers, and social security numbers (“Protected Information”); and
19 WHEREAS, the parties desire to avoid both the necessity of large scale redactions and the
20 unauthorized disclosure or dissemination of this information to anyone not a party to the court
21 proceedings in this matter;
22 The parties agree that entry of a stipulated protective order is appropriate.
23 THEREFORE, Defendant JASON VERTZ, by and through his counsel of record, Assistant
24 Federal Defender Christina M. Corcoran (“Defense Counsel”), and the United States of America, by and
25 through Assistant United States Attorney Alexandre Dempsey, hereby agree and stipulate as follows:
26 1. This Court may enter a protective order pursuant to Rule 16(d) of the Federal Rules of
27 Criminal Procedure, and its general supervisory authority.
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[PROPOSED] PROTECTIVE ORDER 1
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Case 1:21-cr-00054-DAD-BAM Document 13 Filed 03/15/21 Page 2 of 3
1 2. This Order pertains to all discovery provided to or made available to Defense Counsel as
2 part of discovery in this case (hereafter, collectively known as “the discovery”).
3 3. By signing this Stipulation and Protective Order, Defense Counsel agrees not to share any
4 documents that contain Protected Information with anyone other than Defense Counsel attorneys,
5 designated defense investigators, and support staff. Defense Counsel may permit the Defendant to view
6 unredacted documents in the presence of his attorney, defense investigators, and support staff. The
7 parties agree that Defense Counsel, defense investigators, and support staff shall not allow the
8 Defendant to copy Protected Information contained in the discovery. The parties agree that Defense
9 Counsel, defense investigators, and support staff may provide the Defendant with copies of documents
10 from which all Protected Information has been redacted.
11 4. The discovery and information therein may be used only in connection with the litigation
12 of this case and for no other purpose. The discovery is now and will forever remain the property of the
13 United States of America (“Government”). Defense Counsel will return the discovery to the
14 Government or certify that it has been destroyed at the conclusion of the case.
15 5. Defense Counsel will store the discovery in a secure place and will use reasonable care to
16 ensure that it is not disclosed to third persons in violation of this agreement.
17 6. Defense Counsel shall be responsible for advising the Defendant, employees, and other
18 members of the defense team, and defense witnesses of the contents of this Stipulation and Order.
19 7. In the event that Defendant substitutes counsel, undersigned Defense Counsel agrees to
20 withhold discovery from new counsel unless and until substituted counsel agrees also to be bound by
21 this Order.
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[PROPOSED] PROTECTIVE ORDER 2
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Case 1:21-cr-00054-DAD-BAM Document 13 Filed 03/15/21 Page 3 of 3
1 IT IS SO STIPULATED.
2 Dated: March 15, 2021 PHILLIP A. TALBERT
Acting United States Attorney
3
4 By: /s/ALEXANDRE DEMPSEY
ALEXANDRE DEMPSEY
5 Assistant United States Attorney
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7 Dated: March 15, 2021 By: /s/ Christina M. Corcoran________
CHRISTINA CORCORAN
Attorney for Defendant
8 JASON VERTZ
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IT IS SO ORDERED.
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12 Dated: March 15, 2021 /s/ Barbara A. McAuliffe _
UNITED STATES MAGISTRATE JUDGE
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[PROPOSED] PROTECTIVE ORDER 3
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