Stipulation Regarding Protective Order — No. 2:20-cr-00231 (Dkt. 102, D. Nev.)

Summary

A four-page Stipulation Regarding Protective Order with the resulting Protective Order, Document 102, filed 04/26/22 in United States v. Brandon Casutt, No. 2:20-cr-231, in the U.S. District Court for the District of Nevada. Dated the 17th day of March, 2022, the stipulation between the government and the Federal Public Defender counsel for the defendant asks the court to protect the government's sealed Motion in Limine to Limit Cross Examination, related discovery about an expected government trial witness, the briefing and exhibits. The order, signed by District Judge Andrew Gordon on the 26th day of March, 2022, restricts access to the defendant, counsel and their staff and experts, bars copying, sharing or other use, requires sealed filing under LR IC 6-1, and is itself to be filed under seal.

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Cite this document

“Stipulation Regarding Protective Order — No. 2:20-cr-00231 (Dkt. 102, D. Nev.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/stipulation-regarding-protective-order-no-2-20-cr-00231-dkt-102-d-nev-680166c89f/, SHA-256 c4e09d5fb6368a203b74d43cd307b16915e7610659a0d8f4c3f5498e004ab3f4.

Full text

Case 2:20-cr-00231-APG-NJK Document 102 Filed 04/26/22 Page 1 of 4

1 CHRISTOPHER CHIOU
Nevada Bar No. 14853
2 Acting United States Attorney
ERIC C. SCHMALE
3 Assistant United States Attorney
501 Las Vegas Blvd. South, Suite 1100
4 Las Vegas, Nevada 89101
Tel: 702-388-6336
5 eric.schmale@usdoj.gov

6 JOSEPH BEEMSTERBOER
Acting Chief, Fraud Section
7 SARA HALLMARK
Trial Attorney
8 Department of Justice
Fraud Section
9 1400 New York Avenue, NW
Washington, D.C. 20005
10 sara.hallmark2@usdoj.gov

11 Attorneys for the United States

12 UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
13
UNITED STATES OF AMERICA, Case No.: 2:20-cr-231-AGP-NJK
14
Plaintiff, STIPULATION REGARDING
15 PROTECTIVE ORDER
v.
16
BRANDON CASUTT,
17
Defendant.
18

20 IT IS HEREBY STIPULATED AND AGREED, by and between Christopher

21 Chiou, Acting United States Attorney; Eric Schmale, Assistant United States Attorney;

22 Sara Hallmark, Trial Attorney, Fraud Section; and Rene L. Valladares, Federal Public

23 Defender, and Maggie Lambrose, Assistant Federal Public Defender, counsel for the

24 defendant Brandon Casutt, that the Court enter the attached proposed protective order
Case 2:20-cr-00231-APG-NJK Document 102 Filed 04/26/22 Page 2 of 4

1 regarding the government’s concurrently filed under seal Motion in Limine to Limit Cross

2 Examination, related discovery provided regarding the Motion in Limine, any response or

3 reply briefing, and any exhibits thereto, (collectively, the “Protected Motion in Limine

4 Materials”), provided to the defense.

5 This Stipulation is entered into for the following reasons:

6 1. The government is providing the defense with sensitive non-public discovery

7 materials relating to an expected government trial witness;

8 2. The government is filing a sealed motion in limine to limit cross

9 examination with regards to these discovery materials and the expected government trial

10 witness;

11 3. The parties agree that all such Protected Motion in Limine Materials should

12 remain confidential and be treated in accordance with the procedures in the attached

13 proposed protective order.

15 DATED this 17th day of March, 2022.

16 Respectfully submitted,

17 RENE L. VALLADARES NICHOLAS A. TRUTANICH
Federal Public Defender United States Attorney
18
/s/ Maggie Lambrose /s/ Eric Schmale
19 MAGGIE LAMBROSE SARA HALLMARK
Assistant Federal Public Defender Trial Attorney, Fraud Section
20 Counsel for Defendant ERIC C. SCHMALE
Anthony Uvari Assistant United States Attorney
21

2
Case 2:20-cr-00231-APG-NJK Document 102 Filed 04/26/22 Page 3 of 4

1 UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
2
UNITED STATES OF AMERICA, Case No.: 2:20-cr-231-AGP-NJK
3
Plaintiff, PROTECTIVE ORDER
4
v.
5
BRANDON CASUTT,
6
Defendant.
7

8 IT IS HEREBY ORDERED that the following protective measures shall apply with

9 respect to information in the government’s concurrently filed Motion in Limine to Limit

10 Cross Examination, related discovery provided to the defense regarding the Motion in

11 Limine, any response or reply briefing, and any exhibits (the “Protected Materials”):

12 1. Access to the Protected Materials shall be restricted to the following

13 individuals: the named defendant, attorneys for all parties, and any personnel that the

14 attorneys for all parties consider necessary to assist in performing that attorney’s duties in

15 the prosecution or defense of this case, including investigators, paralegals, retained experts,

16 support staff, and any other individuals specifically authorized by the Court (collectively,

17 the “Covered Individuals”).

18 2. The Covered Individuals shall be advised of the Protective Order, and,

19 without leave of Court, the Covered Individuals shall not:

20 a. make copies for, or allow copies of any kind to be made by any other person

21 of the Protected Documents in this case;

22 b. allow any other person to read or review the Protected Materials in this case;

23 c. use the Protected Materials for any purpose other than litigating the charges

24 in this case; or

3
Case 2:20-cr-00231-APG-NJK Document 102 Filed 04/26/22 Page 4 of 4

1 d. attach any Protected Materials to any of the pleadings, briefs, or other court

2 filings except to the extent those pleadings, briefs, or filings are filed under seal or properly

3 compliant with LR IC 6-1.

4 3. Nothing in this stipulation is intended to restrict the Covered Individuals from

5 discussing the content of the Protected Materials with the defendant.

6 4. The parties shall inform any person to whom disclosure may be made

7 pursuant to this order of the existence and terms of this Court’s order.

8 5. The parties further agree that this protective order shall be filed under seal

9 because it discusses matters filed under seal.

10 IT IS SO ORDERED.

11 26th day of March, 2022.
DATED this ______

12
HONORABLE ANDREW GORDON
13 UNITED STATES DISTRICT COURT JUDGE

File and source

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SHA-256: c4e09d5fb6368a203b74d43cd307b16915e7610659a0d8f4c3f5498e004ab3f4
Our copy: 102.pdf
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