United States of America v. $2,757,564.00 In U.S. Currency et al
Filing
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PROTECTIVE ORDER by Magistrate Judge Andrew J. Wistrich re Stipulation for Protective Order: GRANTED (see document for further details) 84 (klg)
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LAW OFFICE OF ERIC HONIG
ERIC HONIG (SBN: 140765)
P.O. Box 10327
Marina Del Rey, CA 90295
erichonig@aol.com
Telephone: (310) 699-8051
Fax: (310) 943-2220
ASTOURIAN & ASSOCIATES, INC.
PARO ASTOURIAN, ESQ. (SBN: 225488)
35 East Union Street, Suite D
Pasadena, CA 91103
Tel: (626) 795-7922
Fax: (626) 795-6884
paro@astourianlaw.com
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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PROTECTIVE ORDER
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Case No. CV 14-2320-FMO (AJWx)
UNITED STATES OF AMERICA,
Plaintiffs,
[Discovery Matter]
v.
19 $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,
23 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 two subpoenas to
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produce documents, information, or objects or to permit inspection on premises in civil action, issued
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on or about November 23, 2016 by the United States of America and directed to Wells Fargo Bank,
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N.A. and MoneyGram Payment Systems Inc. (collectively referred to as the “Subpoenas”) in this
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matter and good cause appearing therefor, the Court hereby ORDERS as follows:
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1.
Documents produced by Wells Fargo Bank, N.A. and/or MoneyGram Payment
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Systems Inc. pursuant to the Subpoenas may include: the personal and private information of the
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claimants Javier Marquez, Romelia Marquez, Abel Marquez and Cynthia Vencebi (collectively,
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“Claimants”) and/or third parties including, but not limited to, personal financial information, names,
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address, telephone numbers, e-mail addresses, social security numbers, driver’s license numbers, dates
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of birth, bank records, bank account numbers, tax return information, and similar types of information
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(collectively, “profile information”).
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2.
Any and all documents produced by Wells Fargo Bank, N.A. and/or MoneyGram
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Payment Systems Inc. pursuant to the Subpoenas shall be designated as confidential only for the
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purposes of this case, and not to disclose the documents to non-parties except as needed for the
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prosecution of the case, and only if the non-party agrees, in writing, to be bound by the terms of a
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protective order prohibiting the disclosure of the documents, or the confidential information contained
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therein, to other third parties. If, however, Wells Fargo produces any documents pursuant to the
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Subpoena that were previously produced by Wells Fargo and/or are already in the possession of the
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government, then the government, from and after the date of production, shall not share those specific
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produced documents with third parties without first providing sufficient notice to Claimants, through
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their counsel Paro Astourian, and the opportunity to have the Court rule on any objections Claimants
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may have.
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3.
Within 90 days of the conclusion of this action (including any appeals), the U.S. shall
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destroy the documents produced by Wells Fargo Bank, N.A. and/or MoneyGram Payment Systems
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Inc. pursuant to the Subpoenas and certify in writing to counsel for the Claimants that the documents
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have been destroyed.
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4.
Absent a further order of the Court, documents produced by Wells Fargo Bank, N.A.
PROTECTIVE ORDER
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and/or MoneyGram Payment Systems Inc. pursuant to the Subpoenas shall not be filed with or
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submitted to the Court, or reproduced in any court filings, unless the documents are placed under seal
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or all profile information or other has been removed.
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5.
Prior to trial, no party shall disclose documents produced by Wells Fargo Bank, N.A.
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and/or MoneyGram Payment Systems Inc. pursuant to the Subpoenas in open court without prior
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consideration by the Court.
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IT IS SO ORDERED.
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Dated: _________________
December 15, 2016
____________________________________________
THE HONORABLE ANDREW J. WISTRICH
UNITED STATES MAGISTRATE JUDGE
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PROTECTIVE ORDER
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