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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
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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
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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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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 ///
///
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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.
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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
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IT IS SO ORDERED:
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12 9-22-25
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14 _________________________________________
HON. MAXIMILIANO D. COUVILLIER III
15 UNITED STATES MAGISTRATE JUDGE
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