United States of America v. 175,121.75 In Wells Fargo Bank Funds

Filing 23

PROTECTIVE ORDER by Judge Manuel L. Real, re Stipulation 22 . See document for details. (gk)

1
2
3
4
5
6
7
8
9
10
11
12
13

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
KATHARINE SCHONBACHLER
Assistant United States Attorney
Asset Forfeiture Section
California Bar No. 222875
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

14
15

UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA

16
WESTERN DIVISION
17
UNITED STATES OF AMERICA,
18

NO. CV 15-07149-R (JCx)

Plaintiff,
19
v.
20
21
22

PROTECTIVE ORDER

$175,121.75 IN WELLS FARGO
BANK FUNDS,
Defendant.

23
24
25

THE MATADOR GROUP, INC.
Claimant.

26
27
28

The Court having reviewed and considered the Stipulation
Re: Protective Order filed by the parties in this matter on

1

March 4, 2016, and good cause appearing, the Court FINDS and

2

ORDERS as follows:
1.

3

On September 10, 2015, the government filed a

4

complaint for forfeiture.

5

claim to the defendant $175,121.75 in Wells Fargo Bank Funds.
2.

6

On December 9, 2015, claimant filed a

The discovery that the government intends to produce

7

to claimant in this matter includes personal identification

8

information for others, including but not limited to names,

9

addresses, telephone numbers, e-mail addresses, social security

10

numbers, driver’s license numbers, phone numbers, dates of

11

birth, bank account numbers and other similar information

12

(collectively “profile information”).
3.

13

Only claimant’s counsel and claimant’s counsel’s

14

employees and retained experts may review the un-redacted

15

discovery, including profile information, in preparation for

16

trial and they may not use the un-redacted profile information

17

or any portion thereof except for the specific purpose of

18

preparing or presenting a defense in this matter.

19

profile information produced to the claimant’s counsel shall be

20

stored in a secure manner.
4.

21

Un-redacted

Claimant may review un-redacted profile information in

22

claimant’s counsel’s office or at the courthouse, and only in

23

the presence of claimant’s counsel and/or claimant’s counsel’s

24

agents.

25

any un-redacted profile information at any time.

26

not take or remove from claimant’s counsel’s office or the

27

courthouse un-redacted profile information.

28

///

Claimant may not possess or in any way make a copy of

2

Claimant may

5.

1

No one other than claimants’ counsel, claimant’s

2

counsel’s employees or retained experts, may review or possess a

3

copy of any un-redacted profile information at any time. If

4

claimant’s counsel deems it appropriate or necessary for

5

claimant to receive some or all of the profile information in

6

this case, claimant’s counsel may, without further Order of the

7

Court, provide only redacted portions of the profile

8

information, where an Assistant United States Attorney or the

9

Court approves the redactions. A willful violation of this

10

Protective Order by claimant, its counsel, or others may result

11

in contempt of court proceedings or other civil or criminal

12

sanctions.

13

///

14

///

15

///

16
17
18
19
20
21
22
23
24
25
26
27
28

3

6.

1

Within 60 days of the conclusion of this matter and

2

the exhaustion of all appeals, claimant’s counsel, claimant’s

3

counsel’s employees, and any retained expert, must either: (1)

4

return all documents containing profile information to the

5

government, as well as all copies, and all notes, memoranda or

6

other documents containing profile information obtained from

7

documents produced in discovery, or (2) destroy the documents

8

containing profile information and certify in writing to counsel

9

for the government that the documents have been destroyed.
IT IS SO ORDERED.

10
11

D

12
13
14

ATED: March 7, 2016
THE HONORABLE MANUEL L. REAL
UNITED STATES DISTRICT JUDGE

15
16
PRESENTED BY:
17
18
19
20
21
22
23
24

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
__/s/_____________________________
KATHARINE SCHONBACHLER
Assistant United States Attorney

25
26

Attorneys for Plaintiff
UNITED STATES OF AMERICA

27
28

4