United States District Court, W.D. Washington
DISCOVERY PROTECTIVE ORDER
C. Coughenour UNITED STATES DISTRICT JUDGE.
matter comes before the Court to on the parties'
stipulated motion for a discovery protective order (Dkt. No.
28). Having considered the motion and the relevant record,
the Court GRANTS the motion and ENTERS the following
following documents and materials are deemed “Protected
Material.” The United States will make available copies
of the Protected Materials, including those filed under seal,
to defense counsel to comply with the Government's
discovery obligations. Possession of copies of the Protected
Materials is limited to the attorneys of record and the
investigators, paralegals, law clerks, experts, and
assistants for the attorneys of record (collectively referred
to as “members of the defense team”). This
category of Protected Materials will be marked and labeled as
a. Grand jury transcripts and exhibits.
b. Audio/video recordings of witnesses and Defendants.
c. Witness and Defendant statements, including, but not
limited to, reports of law enforcement officers memorializing
d. The personal information related to victim/witnesses, and
any statements and documents containing personal information
about or related to any victims and witnesses.
in this order, the term “personal information”
refers to each victim and witness's full name, date of
birth, Social Security number (or other identification
information), driver's license number, address, telephone
number, location of residence or employment, school records,
juvenile criminal records, and other confidential
Scope of Review of Protected Material
attorneys of record and members of the defense teams may
display and review the Protected Material with their
respective Defendant. The attorneys of record and members of
the defense teams agree that providing copies of the
Protected Material to Defendants and other persons is
prohibited and they will not duplicate or provide copies of
Protected Material to Defendants or other persons. The only
exception to this prohibition is that the attorneys of record
and members of the defense teams may provide electronic
copies of Protected Material to the Federal Detention Center
(FDC) at SeaTac, Washington for use in a controlled
environment by their respective Defendant, who is currently
in custody at the FDC.
United States Attorney's Office for the Western District
of Washington is similarly allowed to display and review the
Protected Material with lay witnesses, but is otherwise
prohibited from providing copies of the Protected Material to
lay witnesses, i.e., non-law enforcement witnesses.
Consent to Terms of Protective Order
of the defense team shall provide written consent and
acknowledgement that they will each be bound by the terms and
conditions of this protective order. The written consent need
not be disclosed or produced to the United States unless