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Stipulation for Protective Order; Protective Order — No. 2:25-cr-00191 (Dkt. 7, E.D. Cal.)

Summary

A seven-page Stipulation for Protective Order and Protective Order, Document 7, filed 08/22/25 in United States v. Oleg Gregorvich Fursov, Case No. 2:25-CR-0191 DJC, in the U.S. District Court for the Eastern District of California, signed August 21, 2025 by Assistant U.S. Attorney Jessica Delaney for United States Attorney Eric Grant and by defense counsel Mark Reichel. A grand jury indicted Fursov on August 14, 2025 on a single count of wire fraud under 18 U.S.C. § 1343. The government intends to produce materials holding addresses, phone numbers, Social Security numbers and bank account numbers of witnesses and third parties, and the parties agree to an order under Rule 16(d) and Local Rule 141.1 restricting their use to the Defense Team. Magistrate Judge Carolyn K. Delaney found good cause and entered the order on August 21, 2025.

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“Stipulation for Protective Order; Protective Order — No. 2:25-cr-00191 (Dkt. 7, E.D. Cal.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/stipulation-for-protective-order-protective-order-no-2-25-cr-00191-dkt-5ed0228cfe/, SHA-256 f4abae09fddbf02cfff7909e820a3ea0f4f08618809d9972bf6dbe171400cc30.

Full text

             Case 2:25-cr-00191-DJC            Document 7      Filed 08/22/25   Page 1 of 7

 1 ERIC GRANT
   United States Attorney
 2 JESSICA DELANEY
   Assistant U.S. Attorney
 3 501 I Street, Suite 10-100
   Sacramento, CA 95814
 4 Telephone: (916) 554-2700
   Facsimile: (916) 554-2900
 5

 6 Attorneys for Plaintiff
   United States of America
 7

 8                               IN THE UNITED STATES DISTRICT COURT

 9                                  EASTERN DISTRICT OF CALIFORNIA

10

11   UNITED STATES OF AMERICA,                             CASE NO. 2:25-CR-0191 DJC
12                                Plaintiff,               STIPULATION FOR PROTECTIVE ORDER;
                                                           PROTECTIVE ORDER
13                          v.

14
     OLEG GREGORVICH FURSOV,
15
                                 Defendant.
16

17

18                                             I.   STIPULATION

19          1.     Plaintiff United States of America, by and through its counsel of record, and Defendant

20 Oleg Fursov, by and through his counsel, for the reasons set forth below, hereby stipulate and agree that
21 the Court may and should enter a Protective Order in this case restricting the use and dissemination of

22 certain materials containing personal identifying information of real persons and other confidential

23 information of victims, witnesses, and third parties.

24          2.     On August 14, 2025, the Grand Jury returned an indictment charging a single count of

25 wire fraud in violation of 18 U.S.C. § 1343. As part of its investigation in the above-captioned case, the

26 United States is in possession of materials relating to the charges against Mr. Fursov and seeks to

27 provide those materials to his counsel. Some of the materials may exceed the scope of the United States’

28 discovery obligations but will be produced to promote a prompt and just resolution or trial of the case.


      STIPULATION AND PROTECTIVE ORDER                     1
             Case 2:25-cr-00191-DJC           Document 7       Filed 08/22/25      Page 2 of 7

 1          3.      The United States intends to produce to the Defense Team, as defined below, materials

 2 containing personal identifying information (“PII”) and other confidential information of real persons

 3 and entities, including, among other things, addresses, phone numbers, Social Security numbers, and

 4 bank account numbers. Those real persons and entities are witnesses or third parties to this case.

 5          4.      The purpose of the proposed Protective Order is to prevent the unauthorized

 6 dissemination, distribution, or use of materials containing PII and confidential information of others. If

 7 this information is disclosed without protective measures, or to defendant without limitation, it will risk

 8 the privacy and security of the people to whom the information relates. The information could itself be

 9 used to further criminal activity if improperly disclosed or used. The United States has ongoing statutory

10 and ethical obligations to protect victims.

11          5.      Due to the nature of the charges and the alleged conduct in this case, PII, financial

12 records, and other confidential information make up a significant part of the discovery materials in this

13 case and such information itself, in many instances, has evidentiary value. The documentary evidence

14 contains a large quantity of privacy-protected information that would be difficult or time-consuming to

15 redact. Further, if the government were to attempt to redact all this information, the defense would

16 receive a set of discovery that may be confusing and difficult to understand, and it could inhibit prompt

17 and just resolution of the case or preparation for trial.

18          6.      Accordingly, the parties agree that a Protective Order that will permit the United States to

19 produce discovery that is unredacted but preserve the privacy and security of victims, witness, and third

20 parties, is appropriate. The parties agree that the following conditions, if ordered by the Court in the
21 proposed Protective Order, will serve the government’s interest in maintaining the privacy and security

22 of victims and third parties, while permitting the Defense Team to understand the United States’

23 evidence against the defendant.

24          7.      This Court may enter protective orders pursuant to Rule 16(d) of the Federal Rules of

25 Criminal Procedure, Local Rule 141.1, and its general supervisory authority.

26                               II.      PROPOSED PROTECTIVE ORDER
27          A.      Protected Materials
28          8.      This Order pertains to all discovery provided or made available to defense counsel in this


       STIPULATION AND PROTECTIVE ORDER                   2
             Case 2:25-cr-00191-DJC          Document 7        Filed 08/22/25     Page 3 of 7

 1 case that contains unredacted “Personal Identifying Information” or other confidential third-party

 2 information (collectively, “Protected Materials”).

 3          9.      For purposes of the Protective Order, the term “Personal Identifying Information” (“PII”)

 4 includes any information within the definition of a “means of identification” under 18 U.S.C.

 5 § 1028(d)(7), other than names, and any information within the definition of an “access device” under

 6 18 U.S.C. § 1029(e)(1), for anyone other than the defendant.

 7          10.     To the extent that notes are made that memorialize, in whole or in part, the PII in any

 8 Protected Materials, or to the extent that copies are made for authorized use by members of the Defense

 9 Teams, such notes, copies, or reproductions become Protected Materials, subject to the Protective Order,

10 and must be handled in accordance with the terms of the Protective Order.

11          B.      Defense Team
12          11.     For purposes of this Order, the term “Defense Counsel” refers to the defendant’s counsel

13 of record.

14          12.     For purposes of this Order, the term “Defense Team” refers to (1) Defense Counsel,

15 (2) other attorneys at Defense Counsel’s law firms or defense organizations who may be consulted

16 regarding case strategy in the above-captioned matter, (3) defense investigators who are assisting

17 Defense Counsel with this case, (4) retained experts or potential experts, and (5) paralegals, legal

18 assistants, and other support staff to Defendant’s Counsel assisting on this case. The term “Defense

19 Team” does not include defendants, the defendants’ family, or other associates of the defendant.

20          13.     Defense Counsel must provide a copy of this Order to all members of the Defense Team,

21 prior to providing any Protected Materials to the members of the Defense Team.

22          C.      Disclosure of Protected Materials
23          14.     The Defense Team shall not permit anyone other than the Defense Team to have

24 possession of the Protected Materials, including the defendant.

25          15.     No person or party shall use any Protected Materials or information derived from

26 Protected Materials produced in this action for any purpose other than use in the above-captioned case.

27 All Protected Materials shall be used solely for the purpose of conducting and preparing for pre-trial,

28 post-trial, and appellate proceedings (both direct and collateral) and in this criminal action for no other


      STIPULATION AND PROTECTIVE ORDER                    3
             Case 2:25-cr-00191-DJC         Document 7        Filed 08/22/25    Page 4 of 7

 1 purposes whatsoever, and shall not be used for the economic or other benefit of the defendants, or any

 2 third party. Protected Materials may be disclosed only to the categories of persons and under the

 3 conditions described in this Order.

 4          16.    The defendant may review Protected Materials in this case only in the presence of a

 5 member of his Defense Team, and Defense Counsel shall ensure the defendant is not left alone with any

 6 Protected Materials. The defendant may not copy, keep, maintain, or otherwise possess any of the

 7 Protected Materials. The defendants must return any Protected Materials to his Defense Team at the

 8 conclusion of any meeting at which the defendant reviews the Protected Materials. The defendant may

 9 not take any Protected Materials out of the room in which he is meeting with his Defense Team. The

10 defendant may not write down or memorialize any PII contained in the Protected Materials. At the

11 conclusion of any meeting with the defendant, the member of his Defense Team present shall take with

12 him or her all Protected Materials. At no time, under any circumstances, will Protected Materials be left

13 in the possession, custody, or control of the defendant.

14          17.    The Defense Teams may review Protected Materials with a witness or potential witness

15 in this case, including the defendant, subject to the requirements above that a member of the Defense

16 Team must be present if Protected Materials are being shown to the defendant. Before being shown any

17 portion of the Protected Materials, however, any witness or potential witness must be informed of the

18 existence of the Protective Order and given a copy of the Protective Order. No witness or potential

19 witness (other than members of the Defense Team) may retain Protected Materials, or any copy thereof,

20 after his review of those materials with his Defense Team is complete.
21          18.    This Order does not limit employees of the United States Attorney’s Office for the

22 Eastern District of California from disclosing the Protected Materials to members of the United States

23 Attorney’s Office, law enforcement agencies, the Court, and defense.

24          19.    Defense Counsel shall advise the United States with reasonable notice of any subpoenas,

25 document requests, or claims for access to the Protected Materials by third parties if Defense Counsel is

26 considering disseminating any of the Protected Materials to a third party, so the United States may take

27 action to resist or comply with such demands as it may deem appropriate.

28


      STIPULATION AND PROTECTIVE ORDER                  4
             Case 2:25-cr-00191-DJC           Document 7       Filed 08/22/25      Page 5 of 7

 1          D.       Ensuring Security of Protected Materials

 2          20.      The Defense Team shall maintain the Protected Materials safely and securely and shall

 3 exercise reasonable care in ensuring the security and confidentiality of the Protected Materials by storing

 4 the Protected Materials in a secure place, such as a locked office, or otherwise secure facility where

 5 visitors are not left unescorted.

 6          21.      A copy of the Protective Order must be stored with the discovery, in paper form and

 7 electronically.

 8          22.      To the extent that Protected Materials, or any copies or reproductions thereof, are stored

 9 electronically, the Protected Materials will be stored on a password-protected or encrypted storage

10 medium, including a password-protected computer, or device. Any passwords and encryption keys must

11 be stored securely and not written on the storage media that they unlock.

12          23.      If a member of a Defense Team makes, or causes to be made, any further copies of any of

13 the Protected Materials, Defense Counsel will ensure that the following notation is written, stamped, or

14 inscribed on whatever folder, container, or media contains the copies: “PROTECTED MATERIALS-

15 SUBJECT TO PROTECTIVE ORDER.” For example, if Defense Counsel makes a copy of a disc or

16 physical file containing Protected Materials, the duplicate disc or file must be encrypted and marked

17 with the above notation.

18          E.       Filings

19          24.      In the event a party needs to file Protected Materials containing PII or materials otherwise

20 identified as containing confidential information of victims, witnesses, or third parties with the Court, or
21 disclose PII in court filings, the filing should be made under seal or with all PII or confidential materials

22 redacted. If the Court rejects the request to file such information under seal, the party seeking to file

23 such information shall provide advance written notice to the other party to afford such party an

24 opportunity to object or otherwise respond to such intention. If the other party does not object to the

25 proposed filing, the party seeking to file such information shall redact the PII or confidential materials

26 and make all reasonable attempts to limit the divulging PII or confidential materials.

27          F.       Conclusion of Prosecution

28          25.      The provisions of this Order shall not terminate at the conclusion of this prosecution. All


       STIPULATION AND PROTECTIVE ORDER                   5
             Case 2:25-cr-00191-DJC           Document 7        Filed 08/22/25       Page 6 of 7

 1 Protected Materials subject to the Protective Order maintained in the Defense Team’s files shall remain

 2 subject to the Protective Order unless and until such Order is modified by the Court.

 3          26.     Upon final disposition of the case, including exhaustion of direct and collateral appellate

 4 proceedings, Defense Counsel shall return the Protected Materials to the government, or certify in

 5 writing that the Protected Materials have been destroyed, unless the California Rules of Professional

 6 Conduct, as interpreted by the State Bar of California, require Defense Counsel to retain the material for

 7 a longer duration of time. The written certification need not be disclosed or produced to the United

 8 States unless ordered by the Court.

 9          G.      Termination or Substitution of Counsel
10          27.     In the event there is a substitution of counsel prior to final disposition of the case,

11 new counsel of record must join this Protective Order before any Protected Materials may be transferred

12 from the undersigned defense counsel to the new defense counsel. New defense counsel then will

13 become Defense Counsel for purposes of this Protective Order, and become a Defense Team’s custodian

14 of materials, and shall then become responsible, upon the conclusion of appellate and post-conviction

15 proceedings, for complying with the provisions set forth in this Protective Order. All members of the

16 Defense Team, whether current or past counsel, are at all times subject to the Protective Order and are

17 not relieved by termination of representation or conclusion of the prosecution.

18          H.      Redaction of Protected Materials
19          28.     Nothing in this Order shall prevent the United States Attorney’s Office from redacting

20 PII or other confidential information in any Protected Materials related to the identity of cooperators and
21 informants.

22          I.      Modification of Order
23          29.     Nothing in this Order shall prevent any party from seeking modification of the Order or

24 from objecting to discovery it otherwise believes to be improper. Nothing in this Order shall prevent any

25 party from seeking a more restrictive protective order with regard to particular discovery items.

26          J.      Violation of Order
27          30.     Any person who willfully violates this Order may be held in contempt of court and may

28 be subject to monetary or other sanctions as deemed appropriate by the Court. This provision does not


      STIPULATION AND PROTECTIVE ORDER                     6
             Case 2:25-cr-00191-DJC          Document 7        Filed 08/22/25      Page 7 of 7

 1 expand or narrow the Court’s contempt powers.

 2          K.      Application of Laws
 3          31.     Nothing in this Order shall be construed to affect or comment on the admissibility or

 4 discoverability of the Protected Materials.

 5          32.     Nothing in this Order shall be construed to affect the application of and the parties’

 6 compliance with the Federal Rules of Criminal Procedure, Local Rules, and applicable statutes.

 7

 8    Dated: August 21, 2025                                  ERIC GRANT
                                                              United States Attorney
 9
                                                              /s/JESSICA DELANEY
10                                                            JESSICA DELANEY
                                                              Assistant U.S. Attorney
11
      Dated: August 21, 2025                                  /s/ MARK REICHEL
12                                                            MARK REICHEL
                                                              Counsel for Defendant
13
                                                              OLEG GREGORVICH FURSOV
14

15                                           PROTECTIVE ORDER

16          The Court having read and considered the Stipulation regarding the proposed Protective Order,

17 which this Court incorporates by reference into this Order in full, hereby finds that good cause exists to

18 enter the above Order.

19          IT IS SO FOUND AND ORDERED

20 Dated: August 21, 2025
                                                      _____________________________________
21                                                    CAROLYN K. DELANEY
                                                      UNITED STATES MAGISTRATE JUDGE
22

23

24

25

26

27

28


      STIPULATION AND PROTECTIVE ORDER                    7


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