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United States v. Alebbini

United States District Court, S.D. Ohio, Western Division, Dayton

May 23, 2017

UNITED STATES OF AMERICA, Plaintiff,
v.
LAITH WALEED ALEBBINI, Defendant.

          DEBORAH WILLIAMS Federal Public Defender

          THOMAS ANDERSON Assistant Federal Public Defender Attorney for the Defendant, LAITH WALEED ALEBBINI

          BENJAMIN C. GLASSMAN United States Attorney

          VIPAL J. PATEL, First Assistant United States Attorney

          DOMINICK S. GERACE Assistant United States Attorney

          JUSTIN SHER Trial Attorney National Security Division United States Department of Justice

          PROTECTIVE ORDER GOVERNING DISCOVERY

          HON. WALTER H. RICE UNITED STATES DISTRICT JUDGE

         WHEREAS, the government will provide information and material to the defendant in the course of this case ("Discovery Information"), which may include interviews, reports, audio recordings, photographs, writings, or other discovery materials relating to the case;

         AND WHEREAS, the parties agree that the government has a compelling interest in preventing the Discovery Information from being disclosed to anyone not a party to these judicial proceedings because such material may include information relevant to ongoing investigations and prosecutions, and such material may implicate the privacy interests of the defendant and third parties;

         AND WHEREAS, the parties further agree that the Court has the authority under Fed. R. Crim. P. 16(d)(1) and 26.2 to grant appropriate relief to the parties where required in the interests of justice;

         IT IS HEREBY STIPULATED that:

         1. Except as provided below, Discovery Information shall not be disseminated by the defendant, or his counsel of record, to any individuals, organizations, or other entities, other than: (i) members of the defense team (co-counsel, paralegals, investigators, translators, litigation support personnel, the defendant, and other staff) and (ii) experts retained to assist in the preparation of the defense, or to determine if a plea of guilty is appropriate.[1]

         2. No Discovery Information shall be disseminated to any member of the defense team (including defense-retained expert witnesses), unless that person first signs the attached Acknowledgment. See Attachment A (an agreement to comply with the terms of this Protective Order). The signed Acknowledgment shall be retained by the counsel of record and shall be made available to the Court upon request, and to the government upon reasonable request. The substitution, departure, or removal of counsel for the defendant, or anyone associated with the defense team, for any reason, shall not release that person from the provisions of this Protective Order, or the Acknowledgement executed in connection with this Protective Order.

         3. Defense counsel shall advise any person to whom the Discovery Information is disclosed in accordance with this Protective Order that further disclosure, or dissemination, is prohibited without the defense counsel's express consent, and any disclosure, or dissemination, must comply with the terms of this Protective Order. Each of the individuals to ...


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