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Home Source documents Court filing — United States v. Bock et al. (Feeding Our Future) (Dkt. 130, D. Minn.)

Court filing — United States v. Bock et al. (Feeding Our Future) (Dkt. 130, D. Minn.)

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      CASE 0:22-cr-00223-NEB-DTS           Doc. 130      Filed 11/15/22    Page 1 of 4




                            UNITED STATES DISTRICT COURT
                               DISTRICT OF MINNESOTA


 United States of America,                            Case No. 22-cr-223 (NEB/TNL)

               Plaintiff,

 v.                                                    PROTECTIVE ORDER
                                                      GOVERNING DISCOVERY
 Aimee Marie Bock et al.,

               Defendants.


       This matter comes before the Court on the Government’s Motion for Protective

Order Governing Discovery, ECF No. 123. The Government states that the disclosures

required by Rule 16 of the Federal Rules of Criminal Procedure in this case include highly

sensitive information, including tax records, bank and credit card records, and other

documents and records containing personal financial information and personal identifiable

information of parties and non-parties, including children. The Government further states

that “[w]hile [it] intends to redact a small subset of sensitive information from the

discovery, the redaction of all personal and sensitive information from the discovery would

be impractical and unduly burdensome.” ECF No. 123 at 3. Moreover, “[w]hile the

[G]overnment is prepared to make discovery available to defense counsel for inspection at

its offices, which would satisfy its disclosure obligations under the rules, this would be less

useful to the defense and impractical for both parties.” ECF No. 123 at 3-4. The

Government requests a protective order requiring that certain information be deemed

“Protected Material” and such Protected Material be held in confidence by Defendants and
      CASE 0:22-cr-00223-NEB-DTS           Doc. 130    Filed 11/15/22     Page 2 of 4




their counsel and used “solely for purposes of this litigation.” ECF No. 123 at 4. The

Court directed that any response to the Government’s motion be filed on or before

November 4, 2022. ECF No. 124.

       Under Rule 16(d) of the Federal Rules of Criminal Procedure, “[a]t any time the

court may, for good cause, deny, restrict, or defer discovery or inspection, or grant other

appropriate relief.” Fed. R. Crim. P. 16(d)(1). The Court finds there has been good cause

shown as to why the dissemination of certain highly sensitive information should be

limited.

       Based on the foregoing, and all of the files, records, and proceedings herein, and

pursuant to Fed. R. Crim. P. 16(d), IT IS HEREBY ORDERED that the Government’s

Motion for Protective Order Governing Discovery, ECF No. 123, is GRANTED IN PART

and DENIED IN PART as set forth herein. “Protected Material” as defined below shall

be held in strict confidentiality and used only in connection with the defense of the charges

in this case, and for no other purpose.

       IT IS FURTHER ORDERED:

       1.     “Protected Material” includes all information produced by the Government

in this case and all information produced by the Defendants in this case, except matters of

public record, the Defendants’ own statements, criminal history information, and expert

reports.

       2.     Protected Material shall be held in strict confidentiality by Defendants,

defense counsel, and the Government and may be used solely for purposes of this litigation

in United States v. Aimee Marie Bock et al., No. 22-cr-223 (NEB/TNL).


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          CASE 0:22-cr-00223-NEB-DTS          Doc. 130     Filed 11/15/22     Page 3 of 4




          3.      Defense counsel and counsel for the Government shall limit the making of

copies of the Protected Material to those necessary to their activities as counsel to a party

in this action.

          4.      All individuals having access to Protected Materials, including the

Defendants and any expert witnesses retained by the Defendants and any expert witness or

agent of the Government, shall be informed of the terms of the Protective Order prior to

disclosure.

          5.      Use of the Protected Material covered by this Protective Order for any

purpose other than the instant litigation shall be deemed a violation of this Order subjecting

the violating party and the party’s counsel to sanctions.

          6.      Any filings with the Court that contain Protected Material shall first be

redacted pursuant to Fed. R. Crim. P. 49.1 or, if not redacted, then filed under seal in

accordance with the Court’s sealing rules and applicable filing procedures.

          7.      Any documents or other materials containing Protected Material, and all

copies of them, must be destroyed or returned to the party that provided them within 60

days of the conclusion of this litigation, including appeals.

          8.      Nothing contained in this Order shall preclude any party from applying to

this Court for further relief or for modification of any provision hereof.

          9.      All prior consistent orders relating to the Indictment remain in full force and

effect.




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      CASE 0:22-cr-00223-NEB-DTS          Doc. 130    Filed 11/15/22     Page 4 of 4




       10.    Failure to comply with any provision of this Order or any other prior

consistent Order shall subject the non-complying party, non-complying counsel and/or the

party such counsel represents to any and all appropriate remedies, sanctions and the like.



Dated: November      15     , 2022                      s/ Tony N. Leung
                                                 Tony N. Leung
                                                 United States Magistrate Judge
                                                 District of Minnesota


                                                 United States v. Bock et al.
                                                 Case No. 22-cr-223 (NEB/TNL)




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