United States of America v. $2,757,564.00 In U.S. Currency et al

Filing 62

PROTECTIVE ORDER by Magistrate Judge Andrew J. Wistrich re: Stipulation for Protective Order 61 . (See document for complete details). (klg)

1
2
3
4
5
6
7
8
9
10
11
12

EILEEN M. DECKER
United States Attorney
LAWRENCE S. MIDDLETON
Assistant United States Attorney
Chief, Criminal Division
STEVEN R. WELK
Assistant United States Attorney
Chief, Asset Forfeiture Section
VICTOR A. RODGERS
California Bar No. 101281
Assistant United States Attorney
Asset Forfeiture Section
Federal Courthouse, 14th Floor
312 North Spring Street
Los Angeles, California 90012
Telephone: [phone]
Facsimile: [phone]
E-mail:
[e-mail]
Attorneys for Plaintiff
UNITED STATES OF AMERICA
UNITED STATES DISTRICT COURT

13

FOR THE CENTRAL DISTRICT OF CALIFORNIA

14

WESTERN DIVISON

15
16

UNITED STATES OF AMERICA,

17
18
19
20

Plaintiff,

Case No. CV 14-02320 FMO(AJWx)
PROTECTIVE ORDER
[Discovery Matter]

v.
$2,757,564.00 IN U.S. CURRENCY
AND TWO ITEMS OF JEWELRY,
Defendants.

21
22
23
24

JAVIER MARQUEZ, ROMELIA
MARQUEZ, ABEL MARQUEZ, AND
CYNTHIA VENCEBI,
Claimants.

25
26
27
28

The Court’s having considered the stipulation of the
parties with respect to the disclosure of information in

1

discovery in this matter and good cause appearing therefor, the

2

Court hereby ORDERS as follows:

3

1.

The government may produce to the claimants discovery

4

in this matter that includes personal identification for others,

5

including but not limited to names, addresses, telephone

6

numbers, e-mail addresses, social security numbers, driver’s

7

license numbers, telephone numbers, dates of birth, bank account

8

numbers and other similar information, as well as financial

9

information, including bank records that contain personal

10

identifying information, including home addresses, Social

11

Security numbers, bank account numbers and other data

12

(collectively, “profile information”).

13

2.

The government shall identify such information in

14

discovery by using the following designation on the documents,

15

on a diskette cover, or in an accompanying cover letter:

16

“CONFIDENTIAL INFORMATION – SUBJECT TO PROTECTIVE ORDER.”

17

3.

Claimants and their counsel shall use documents that

18

are so designated only for the purposes of this case and shall

19

not disclose the documents to non-parties, except as needed for

20

the defense of the case, and only if the non-party agrees, in

21

writing, to be bound by the terms of a protective order

22

prohibiting the disclosure of the documents, or the confidential

23

information contained therein, to other third parties.

24

4.

Within 90 days of the conclusion of this action

25

(including any appeals), claimants shall either (1) return all

26

designated documents to the government, as well as all copies

27

and all notes, memoranda, or other documents containing

28

confidential information obtained from the designated documents,
2

1

or (2) destroy the documents and certify in writing to counsel

2

for the government that the documents have been destroyed.

3

5.

Absent a further order of the Court, designated

4

documents shall not be filed with or submitted to the Court, or

5

reproduced in any court filing, unless the documents are placed

6

under seal or all prior information or other personal

7

identifying information has been removed.

8
9
10
11
12

6.

Prior to trial, no party shall disclose designated

documents in open court without prior consideration by the
Court.
IT IS SO ORDERED.
Dated: _08/17/2016 _____

13

______________
____________
THE HONORABLE ANDREW J. WISTRICH
UNITED STATES MAGISTRATE JUDGE

14
15

Submitted By:

16

EILEEN M. DECKER
United States Attorney
LAWRENCE S. MIDDLETON
Assistant United states Attorney
Chief, Criminal Division
STEVEN R. WELK
Assistant United States Attorney
Chief, Asset Forfeiture Section

17
18
19
20
21
22
23

/s/ Victor A. Rodgers
_
VICTOR A. RODGERS
Assistant United States Attorney
Attorneys for Plaintiff
UNITED STATES OF AMERICA

24
25
26
27
28
3