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United States v. Cota-Muniz

United States District Court, W.D. Washington

May 2, 2017

UNITED STATES OF AMERICA, Plaintiff,
v.
ANGEL L. COTA-MUNIZ, EDGAR D. BARRON-GONZALEZ, JESSICA L. ASHBY, Defendants.

          DISCOVERY PROTECTIVE ORDER

          John C. Coughenour UNITED STATES DISTRICT JUDGE.

         This 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 protective order:

         1. Protected Material

         The 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 “Protected Material”:

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 witness statements.
d. The personal information related to victim/witnesses, and any statements and documents containing personal information about or related to any victims and witnesses.

         As used 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 information.

         2. Scope of Review of Protected Material

         The 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.

         The 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.

         3. Consent to Terms of Protective Order

         Members 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 ...


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