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United States v. Goddard

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

December 31, 2019

UNITED STATES OF AMERICA,
v.
NATHAN GODDARD, ET Al., Defendants.

          DAVID M. DEVILLERS UNITED STATES ATTORNEY

          DENNIS A. LIEBERMAN JAMES M. CALHOUN II ATTORNEYS FOR DEFENDANT CORTNER

          JAMES P. FLEISHER ATTORNEY FOR DEFENDANT COMBS

          TAMARA S. SACK DONALD J. MALARCIK ATTORNEYS FOR DEFENDANT GODDARD

          DOMINICK S. GERACE BRENT G. TABACCHI ASSISTANT UNITED STATES ATTORNEYS

          PROTECTIVE ORDER GOVERNING DISCOVERY

          HON. THOMAS M. ROSE UNITED STATES DISTRICT JUDGE

         WHEREAS, the government will provide information and material to the defendants 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 defendants 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. Discovery Information shall not be disseminated by the defendants, or defendants' counsel of record, to any individuals, organizations, or other entities, other than: (i) members of each defendant's defense team (co-counsel, paralegals, investigators, translators, litigation support personnel, the defendants (subject to paragraph 4, below), appellate and post-conviction counsel, and other defense staff); (ii) experts retained to assist in the preparation of the defense; and (iii) with respect to any individuals, organizations, or other entities not covered in subsections (i) and (ii) of this paragraph, with the express concurrence of the government.[1]

         2. No Discovery Information shall be disseminated to any member of a defendant's defense team or appellate or post-conviction counsel (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 defendants, or anyone associated with a defendant's 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 whom disclosure is made pursuant to this provision shall be provided a copy of this Protective Order.

         4. Discovery Information shall not be given to the defendants to maintain, and the defendants shall not be permitted to make notes of the content of the Discovery Information, and shall not keep such notes with them, or disperse such notes, or the contents thereof, to anyone other than individuals ...


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