United States District Court, W.D. Washington
DISCOVERY PROTECTIVE ORDER
Honorable Robert S. Lasnik Judge.
Honorable Robert S. Lasnik This matter, having come to the
Court's attention on the United States' Renewed and
Revised Motion for Entry of a Discovery Protective Order, and
the Court, having considered the motion, and being fully
advised in this matter, hereby finds, FOR THE REASONS stated
in the United States' Renewed Motion, there is a factual
basis to support the United States' concerns, and there
is good cause for the requested Discovery Protective Order in
order to advance the goals of protecting a confidential
source from disclosure of personal information, protecting
ongoing investigations, and avoiding the potential for
harassment, tampering, or retaliation.
Court therefore grants the Renewed Motion and enters the
following Protective Order;
United States will make available copies of Protected
Materials, including those filed tinder seal, to defense
counsel to comply with the government's discovery
obligations. Possession of copies of the Protected Materials
is limited to the defense attorneys of record, and
investigators, paralegals, law clerks, experts and assistants
for the defense attorneys of record (hereinafter collectively
referred to as members of the defense team). Protected
Materials will be marked and labeled as "Protected
Material, " including:
a. Audio, video, photographic, and written recordings of the
confidential source ("CS") used by Homeland
Security Investigations in investigating this case;
b. Personal information related to the CS, including any
documents provided by the government containing personal
information about or related to the CS.
in this Order, the term "personal information"
includes a person's full name, picture or likeness, voice
recording, 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.
Scope of Review of Protected Material
attorneys of record and members of the defense team may
display and review the Protected Material with Defendants.
The attorneys of record and members of the defense team 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 and
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
requested by the Assistant United States Attorney and ordered
by the Court.
Parties' Reciprocal ...