Case 1:22-cr-00129-DAD-BAM Document 21 Filed 06/02/22 Page 1 of 4
1 PHILLIP A. TALBERT
United States Attorney
2 JOSEPH D. BARTON
Assistant United States Attorney
3 2500 Tulare Street, Suite 4401
Fresno, CA 93721
4 Telephone: (559) 497-4000
Facsimile: (559) 497-4099
5
6 Attorneys for Plaintiff
United States of America
7
8 IN THE UNITED STATES DISTRICT COURT
9 EASTERN DISTRICT OF CALIFORNIA
10
UNITED STATES OF AMERICA, CASE NO. 1:22-CR-00129-DAD-BAM
11
Plaintiff, STIPULATION BETWEEN THE PARTIES
12 REGARDING PROTECTED INFORMATION
v.
13
APRYL WESTON,
14
Defendant.
15
16
17 WHEREAS, the discovery in this case contains a large amount of personal information including
18 Social Security numbers, personal identification numbers, dates of birth, financial account numbers,
19 telephone numbers, and residential addresses (“Protected Information”); and
20 WHEREAS, the parties desire to avoid both the necessity of large scale redactions and the
21 unauthorized disclosure or dissemination of this information to anyone not a party to the court
22 proceedings in this matter;
23 The parties agree that entry of a stipulated protective order is appropriate.
24 THEREFORE, the defendant APRYL WESTON, by and through her counsel of record
25 (“Defense Counsel”), and plaintiff the UNITED STATES, by and through its counsel of record, hereby
26 agree and stipulate as follows:
27 1. This Court may enter a protective order pursuant to Rule 16(d) of the Federal Rules of
28 Criminal Procedure and its general supervisory authority;
STIPULATION AND ORDER 1
30
Case 1:22-cr-00129-DAD-BAM Document 21 Filed 06/02/22 Page 2 of 4
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, Defense Counsel agrees not to share any documents that
4 contain Protected Information with anyone other than Defense Counsel and designated defense
5 investigators and support staff. Defense Counsel may permit the defendant to view unredacted
6 documents in the presence of her attorney, defense investigators, and support staff. The parties agree
7 that Defense Counsel, defense investigators, and support staff shall not allow the defendant to copy
8 Protected Information contained in the discovery. The parties agree that Defense Counsel, defense
9 investigators, and support staff may provide the defendant with copies of documents from which
10 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 including exhaustion of direct and collateral appellate proceedings and for no other purpose.
13 The discovery is now and will forever remain the property of the Government. Defense Counsel will
14 return the discovery to the Government or certify that it has been destroyed at the conclusion of the case
15 including exhaustion of direct and collateral appellate proceedings;
16 5. Defense Counsel will store the discovery in a secure place and will use reasonable care to
17 ensure that it is not disclosed to third persons in violation of this agreement;
18 6. Defense Counsel shall be responsible for advising the defendant, as well as Defense
19 Counsel’s employees, other members of the defense team, and defense witnesses, of the contents of this
20 Stipulation and Order; and
21 7. In the event that the defendant substitutes counsel, undersigned Defense Counsel agrees
22 to withhold discovery from any new counsel unless and until substituted counsel agrees also to be bound
23 by this Stipulation and Order.
24 ///
25 ///
26 ///
27
28
STIPULATION AND ORDER 2
30
Case 1:22-cr-00129-DAD-BAM Document 21 Filed 06/02/22 Page 3 of 4
1 IT IS SO STIPULATED.
2
3 DATED: June 1, 2022
4
5 /s/ Erin Snider
ERIN SNIDER
6 COUNSEL FOR MAKIAH MILES
7
8
/s/ Joseph Barton
9 JOSEPH BARTON
COUNSEL FOR UNITED STATES
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
STIPULATION AND ORDER 3
30
Case 1:22-cr-00129-DAD-BAM Document 21 Filed 06/02/22 Page 4 of 4
1 PHILLIP A. TALBERT
United States Attorney
2 JOSEPH D. BARTON
Assistant United States Attorney
3 2500 Tulare Street, Suite 4401
Fresno, CA 93721
4 Telephone: (559) 497-4000
Facsimile: (559) 497-4099
5
6 Attorneys for Plaintiff
United States of America
7
8 IN THE UNITED STATES DISTRICT COURT
9 EASTERN DISTRICT OF CALIFORNIA
10
UNITED STATES OF AMERICA, CASE NO. 1:22-CR-00129-DAD-BAM
11
Plaintiff, PROTECTIVE ORDER BETWEEN THE
12 PARTIES REGARDING PROTECTED
v. INFORMATION
13
APRYL WESTON,
14
Defendants.
15
16
17 ORDER
18 For good cause shown, the stipulation between counsel dated June 1, 2022, in Case No. 1:22-cr-
19
00129-DAD-BAM, regarding discovery and treatment of Protected Information is approved.
20
21 IT IS SO ORDERED.
22
Dated: June 2, 2022 /s/ Barbara A. McAuliffe _
23 UNITED STATES MAGISTRATE JUDGE
24
25
26
27
28
STIPULATION AND ORDER 4
30