Stipulated Protective Order — No. 5:25-cr-20543 (Dkt. 17, E.D. Mich.)

Summary

A five-page Stipulated Protective Order, ECF No. 17, filed 09/13/25 in United States v. Cemhan Jimmy Biricik and Martin Perlin, M.D., Criminal No. 25-cr-20543, before Judge Judith E. Levy in the U.S. District Court for the Eastern District of Michigan, stipulated on September 10, 2025 by Assistant United States Attorneys Regina R. McCullough and Ryan A. Particka and defense counsel, and ordered on September 13, 2025. Because discovery includes confidential law enforcement materials, third parties' personal identifying and health information, account numbers and proprietary business data too voluminous to redact, the order under Rule 16(d) limits viewing to defense counsel, investigators and staff; a defendant may see unredacted files only in counsel's presence and may keep only redacted copies. Materials must be returned or deleted at the end of the case.

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 Case 5:25-cr-20543-JEL-KGA ECF No. 17, PageID.55 Filed 09/13/25 Page 1 of 5




                     UNITED STATES DISTRICT COURT
                     EASTERN DISTRICT OF MICHIGAN
                          SOUTHERN DIVISION
UNITED STATES OF AMERICA,
      Plaintiff,                             Criminal No. 25-cr-20543
      v.                                     Hon. Judith E. Levy

D-1 CEMHAN “JIMMY” BIRICIK,
D-2 MARTIN PERLIN, M.D.

     Defendants.
___________________________________/


                    STIPULATED PROTECTIVE ORDER


      The parties, by and through their undersigned counsel, stipulate and agree as

follows.

1.    The government will produce discovery in this matter that includes (i)

confidential law enforcement materials (including but not limited to confidential

source information); (ii) the personal identifying information of third parties and

confidential health information of those individuals (“PII”), which may include, but

is not limited to, social security numbers, dates of birth, telephone numbers,

addresses; (iii) financial information (such as account numbers); (iv) proprietary

business information; and (v) personal health and medical records.

2.    The voluminous amount of discovery in this matter makes the redaction of PII

impractical prior to production as discovery. The parties understand that such PII
 Case 5:25-cr-20543-JEL-KGA ECF No. 17, PageID.56 Filed 09/13/25 Page 2 of 5




and the confidential law enforcement materials, as contained in the discovery, should

be protected from use and disclosure beyond what is reasonably necessary for the

effective defense of this matter.

3.    Therefore, the parties respectfully request that the Court enter this Stipulated

Protective Order (“Order”) pursuant to Rule 16(d) of the Federal Rules of Criminal

Procedure. This Order pertains to all discovery provided to or made available to

defense counsel as part of discovery in this matter.

4.    By signing the Order, defense counsel agrees that any documents or files

containing confidential law enforcement materials or PII are to be viewed only by

defense counsel, designated defense investigators, support staff, or other individuals

necessary for assisting defense in the preparation and trial for this matter. Defense

counsel may permit their client to view confidential materials or unredacted PII files

only in the presence of their attorney, defense investigators, and/or support staff in

the office of defense counsel or at the detention facility where the defendant is being

housed. However, confidential materials or unredacted PII files may not be

disseminated to, or by, the defendant or between defendants, or any other person, in

any circumstance.

5.    The defendant shall not be permitted to keep or take with the defendant

confidential law enforcement materials, unredacted copies of files containing PII, or

possess notes containing PII obtained from such files. All defendants shall be
 Case 5:25-cr-20543-JEL-KGA ECF No. 17, PageID.57 Filed 09/13/25 Page 3 of 5




permitted to keep and review redacted copies of documents with PII removed and

possess notes not containing PII or confidential law enforcement information.

6.    The parties agree that no individuals outside of those listed above are to

review, receive and/or otherwise view any discovery materials in this case.

7.    The discovery and information therein may only be used in connection with

the litigation of this case and for no other purpose. The discovery is now and will

forever remain the property of the United States Government.

8.    Defense counsel shall return the electronic discovery to the government at the

conclusion of this case and/or permanently delete any copies from their computer

systems. If any defense counsel, defense investigator, or support staff has produced

any electronic discovery, the electronic discovery shall be deleted or returned to the

government. If any defense counsel, defense investigator, or support staff has

produced hard copies of the discovery, the hard copies shall be shredded. Within 90

days following the conclusion of all litigation in this matter (including time for any

appeals), defense counsel shall certify in writing to counsel for the United States that

all of the discovery has been returned, destroyed, and/or shredded.

9.    In the event the defense seeks utilization of the discovery material in any court

filing, at trial or in another hearing in this matter, any PII must be redacted from the

discovery prior to its use. Any filings shall comply with Rule 49.1 of the Federal

Rules of Criminal Procedure and the electronic filing policies and procedures of the
 Case 5:25-cr-20543-JEL-KGA ECF No. 17, PageID.58 Filed 09/13/25 Page 4 of 5




United States District Court for the Eastern District of Michigan.

10.   Defense counsel shall be responsible for advising their client, defense

investigators, support staff, and other members of the defense team of the contents

of this Order and shall instruct such persons that disclosure of the discovery material

beyond that allowed by this Order is prohibited. Any unauthorized disclosure may

constitute a violation of this Order.

11.   In the event that the defendant substitutes counsel, undersigned defense

counsel agrees to withhold discovery from new counsel unless and until substituted

counsel agrees also to be bound by this Order.



IT IS SO STIPULATED.

Dated: September 10, 2025


JEROME F. GORGON JR.
United States Attorney

 s/Regina R. McCullough                        s/Ryan A. Particka
 Regina R. McCullough                          Ryan A. Particka
 Assistant United Attorney                     Assistant United States Attorney
 United States Attorney's Office               United States Attorney’s Office
 211 W. Fort Street, Suite 2001                211 W. Fort Street, Suite 2001
 Detroit, MI 48226                             Detroit, MI 48226
 313-226-9618                                  313-226-9635
 Regina.Mccullough@usdoj.gov                   Ryan.particka@usdoj.gov
 Case 5:25-cr-20543-JEL-KGA ECF No. 17, PageID.59 Filed 09/13/25 Page 5 of 5




s/John Freeman                            s/Jeffrey Chabrowe
John Freeman                              Jeffrey Chabrowe
Counsel for Defendant Cemhan Biricik      Counsel for Defendant Cemhan Biricik
1760 S. Telegraph, Suite 303              521 5th Ave., Suite 1729
Bloomfield Hills, MI 48302                New York, N.Y. 10175
248-952-9351                              212-235-1510
John@formerfedlawyer.com                  Jeff@Chabrowe.com

s/Ronald Chapman, II
Ronald Chapman, II
Counsel for Dr. Martin Perlin
1441 W. Long Lake Rd., Suite 310
Troy, MI 48098
248-644-6326
RWChapman@Chapmanlawgroup.com




IT IS SO ORDERED.
Date: September 13, 2025                 s/Judith E. Levy
                                         JUDITH E. LEVY
                                         United States District Judge


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