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

Filing 69

PROTECTIVE ORDER by Magistrate Judge Andrew J. Wistrich re Stipulation for Protective Order 68 . (see document for details) (jsan)

1 LAW OFFICE OF ERIC HONIG
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ERIC HONIG (SBN: 140765)
P.O. Box 10327
Marina Del Rey, CA 90295
[e-mail]
Telephone: [phone]
Fax: [phone]

ASTOURIAN & ASSOCIATES, INC.
PARO ASTOURIAN, ESQ. (SBN: 225488)
35 East Union Street, Suite D
Pasadena, CA 91103
Tel: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Claimants
Javier Marquez, Romelia Marquez, Abel Marquez, and Cynthia Vencebi

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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WESTERN DIVISION

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Case No. CV 14-2320-FMO (AJWx)

UNITED STATES OF AMERICA,

PROTECTIVE ORDER

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Plaintiffs,
[Discovery Matter]

v.

20 $2,757,564.00 IN U.S. CURRENCY AND
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TWO ITEMS OF JEWELRY,
Defendants.

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JAVIER MARQUEZ, ROMELIA MARQUEZ,
24 ABEL MARQUEZ and CYNTHIA VENCEBI,

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Claimants.

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PROTECTIVE ORDER

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The Court, having considered the stipulation of the parties with respect to the disclosure of

3 information in discovery in this matter and good cause appearing therefor, the Court hereby ORDERS
4 as follows:
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1.

The claimants Javier Marquez, Romelia Marquez, Abel Marquez and Cythia Vencebi

6 (collectively, “Claimants”) may produce to the United States of America (the “U.S.”) discovery in this
7 matter that includes: the personal and private information of the Claimants and/or third parties
8 including, but not limited to, personal financial information, names, address, telephone numbers, e9 mail addresses, social security numbers, driver’s license numbers, telephone numbers, dates of birth,
10 bank records, bank account numbers, tax return information, and similar types of information
11 (collectively, “profile information”).
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2.

The Claimants shall identify such information in discovery by using the following

13 designation on the documents, on a diskette cover, or in an accompanying cover letter:
14 “CONFIDENTIAL INFORMATION – SUBJECT TO PROTECTIVE ORDER.”
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3.

The U.S. and its counsel shall use the documents that are designated as confidential

16 only for the purposes of this case, and shall not disclose the documents to non-parties except as needed
17 for the prosecution of the case, and only if the non-party agrees, in writing, to be bound by the terms of
18 a protective order prohibiting the disclosure of the documents, or the confidential information
19 contained therein, to other third parties.
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4.

Within 90 days of the conclusion of this action (including any appeals), the U.S. shall

21 either: (1) return all designated documents to the Claimants, as well as all copies of all notes,
22 memoranda, or other documents containing confidential information obtained from the designated
23 documents, or (2) destroy the documents and certify in writing to counsel for the Claimants that the
24 documents have been destroyed.
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5.

Absent a further order of the Court, designated documents shall not be filed with or

26 submitted to the Court, or reproduced in any court filings, unless the documents are placed under seal
27 or all profile information or other has been removed.
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6.

Prior to trial, no party shall disclose designated documents in open court without prior

PROTECTIVE ORDER

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1 consideration by the Court.
2 IT IS SO ORDERD.
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4 Dated: October 20, 2016
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____________________________________________
THE HONORABLE ANDREW J. WISTRICH
UNITED STATES MAGISTRATE JUDGE

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PROTECTIVE ORDER

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