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United States v. Wang

United States District Court, W.D. Washington, Seattle

May 28, 2017

UNITED STATES OF AMERICA, Plaintiff,
v.
FANG WANG, et al., Defendants.

          CATHERINE L. CRISHAM Assistant United States Attorney.

          PROTECTIVE ORDER.

          THE HONORABLE THOMAS S. ZILLY UNITED STATES DISTRICT COURT JUDGE.

         This matter, having come to the Court's attention on the parties' joint motion for entry of a discovery protective order, and the Court, having considered the motion, and being fully advised in this matter, hereby enters the following PROTECTIVE ORDER:

         1. Protected and Sensitive Material.

         A. Protected Material. The following documents and materials shall be designated as Protected Material:

         i. Grand Jury transcripts and exhibits;

         ii. Witness statements, including but not limited to reports of law enforcement officers memorializing witness statements; and

         iii. The personal information related to victims and/or witnesses, and any statements and/or documents containing personal information related to any victims and/or witnesses. As used in this Order, the term "personal information" refers to each victim and/or witnesses' 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. In addition, with respect to any victims in this case, the term "personal information" also includes the name and identity of each victim.

         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 investigators, paralegals, law clerks, experts and assistants for the attorneys of record (hereinafter collectively referred to as "members of the defense teams"):

         The attorneys of record and members of each Defendant's defense team may share and review the Protected Material with their respective Defendant. The attorneys of record and members of the defense team acknowledge that providing copies of the Protected Material to the Defendants and other persons is prohibited, and agree not to duplicate or provide copies of the Protected Material to the Defendants and other persons. The exception to this prohibition is the dissemination of electronic copies to the Federal Detention Center at SeaTac, Washington, for use in a controlled environment by any Defendants who may in custody there. The United States Attorney's Office for the Western District of Washington is prohibited from providing copies of the Protected Material to non-law enforcement witnesses or potential witnesses.

         B. Sensitive Material. The following documents and materials shall be designated as Sensitive Material:

         i. Medical records related to victims and/or witnesses; and

         ii. Unredacted sexually suggestive photographs of victims and/or witnesses, including but not limited to photographs connected to online advertisements for prostitution.

         Possession of Sensitive Material is limited to attorneys of record and members of the defense teams. The attorneys of record and members of the defense teams may not share or review the documents containing Sensitive Material, or any copies of any documents containing Sensitive Material, in any manner with any other person, including Defendants. This order, however, does not prohibit attorneys of record and members of the defense team from discussing the contents of documents constituting Sensitive Material with Defendants, as long as the attorneys of record and members of the defense teams do not share the documents or copies of the documents with Defendants or any other person. The attorneys of record and members of the defense teams shall keep any documents containing Sensitive Material secured whenever the documents containing Sensitive Material are not being used in furtherance of their work in the above captioned case, The Government shall clearly label each page of Protected or Sensitive Material with the words "Protected" or "Sensitive, " respectively. Pages that are not clearly labeled as such will not be ...


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