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Court filing — No. 2:25-cr-00241 (Dkt. 18)

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         Case 2:25-cr-00241-RFB-MDC           Document 18       Filed 09/22/25     Page 1 of 4




 1   SIGAL CHATTAH
     Acting United States Attorney
 2   Nevada Bar Number 7709
     MINA CHANG
 3   Assistant United States Attorney
     501 Las Vegas Boulevard South, Suite 1100
 4   Las Vegas, Nevada 89101
     Tel: 702.388.6336 / Fax: 702.388.6418
 5   mina.chang@usdoj.gov
     Attorneys for the United States
 6
                                 UNITED STATES DISTRICT COURT
 7                                    DISTRICT OF NEVADA

 8   UNITED STATES OF AMERICA,                             No. 2:25-cr-00241-RFB-MDC

 9                  Plaintiff,                             Stipulation and Protective Order

10          v.

11   CRAIG RENARD GIBSON,

12                  Defendant.

13

14          The United States, by and between Sigal Chattah, Acting United States Attorney,

15   and Mina Chang, Assistant United States Attorney, counsel for the United States of

16   America, and Charles Goodwin, Esq., counsel for Defendant Craig Renard Gibson,

17   respectfully move for the entry of a Protective Order governing discovery in this matter in

18   accord with the following Stipulation:

19                                            STIPULATION

20          Whereas, the parties recognize that various federal and state laws and regulations

21   extend protections and limitations regarding the use, disclosure, or publication of

22   information associated with the privacy and identity of an individual, including, but not

23   limited to, social security number, date of birth, address, telephone number, driver’s license

24
         Case 2:25-cr-00241-RFB-MDC            Document 18      Filed 09/22/25     Page 2 of 4




1    number, financial information, banking information, and tax information, which is

2    hereinafter collectively referred to as “Protected Personal Information” (“PPI”);

3           Whereas, the parties recognize that discovery in the above-captioned case is likely to

4    be voluminous and may include documents and other evidence containing PPI of third

5    parties;

6           Whereas, the parties desire to provide for the timely and expeditious exchange of

7    discovery while simultaneously guarding against the inappropriate use, disclosure, or

8    publication of any PPI associated with any party or third party;

9           Whereas, in light of the above, the parties have conferred on this matter and have

10   reached agreement on the exchange and handling of PPI;

11          IT IS HEREBY STIPULATED AND AGREED by and between the undersigned

12   parties, as follows:

13                  1. Documents containing PPI will be referred to as “Protected Documents.”

14                  2. The government may produce Protected Documents to the defendant in

15                      discovery without redacting PPI.

16                  3. Access to Protected Documents produced by the government will be

17                      restricted to the defendant, attorneys for the defendant, and any agents,

18                      contractors, or employees acting on behalf of the defendant and/or their

19                      attorneys in connection with the above-captioned matter (hereinafter

20                      referred to collectively as “Authorized Person(s)”).

21                  4. Unless otherwise Ordered by the Court, an Authorized Person shall not:

22                          a. grant or permit access to Protected Documents by any non-

23                             Authorized Person.

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       Case 2:25-cr-00241-RFB-MDC          Document 18     Filed 09/22/25     Page 3 of 4




1                   b. allow or permit any non-Authorized Person to read, review, or

2                       reproduce any Protected Document.

3                   c. distribute any Protected Document, by any means, to any non-

4                       Authorized Person.

5                   d. use or disclose Protected Documents, and any PPI contained

6                       therein, for any purpose other than in connection with the defense

7                       of the above-captioned matter.

8                   e. use or disclose a Protected Document in connection with any

9                       pleadings or proceedings in the above-captioned matter without

10                      first redacting any PPI, unless the PPI is directly relevant to the

11                      matter at issue.

12                  f. use or disclose PPI in connection with any pleadings or

13                      proceedings in the above-captioned matter, unless the PPI is

14                      directly relevant to the matter at issue.

15            5. Upon conclusion of the above-captioned matter, the defendant’s attorney

16               shall return any and all copies of Protected Documents to the attorneys for

17               the United States, or provide them with written certification that the

18               Protected Documents have been destroyed.

19            6. Nothing in the agreement shall be deemed an admission of the evidentiary

20               admissibility or inadmissibility of any Protected Document in any

21               subsequent proceeding.

22   ///

23   ///

     ///
24


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         Case 2:25-cr-00241-RFB-MDC           Document 18       Filed 09/22/25      Page 4 of 4




1           WHEREFORE, the undersigned respectfully request that the Court accept and enter

2    this Stipulation as the Protective Order governing discovery in this case.

3

4    DATED this 4th day of September, 2025.

5                                               Respectfully submitted,

6                                                SIGAL CHATTAH
                                                 Acting United States Attorney
7
          /s/ Charles R. Goodwin                     /s/ Mina Chang
8     CHARLES GOODWIN, ESQ.                      MINA CHANG
      Counsel for Defendant Gibson               Assistant United States Attorney
9                                                Counsel for the United States

10
     IT IS SO ORDERED:
11

12          9-22-25

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14                                             _________________________________________
                                                HON. MAXIMILIANO D. COUVILLIER III
15                                              UNITED STATES MAGISTRATE JUDGE

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