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STIPULATION AND PROTECTIVE ORDER

[09-0749 RS]

JOSEPH P. RUSSONIELLO (CABN 44332)

United States Attorney

BRIAN J. STRETCH (CABN 163973)

Chief, Criminal Division

CHRISTINE Y. WONG (NYBN 3988607)

Assistant United States Attorney

450 Golden Gate Avenue, Box 36055

San Francisco, California 94102

Telephone: (415) 436-7301

Facsimile: (415) 436-6753

E-Mail: Christine.Wong@usdoj.gov

Attorneys for the United States of America

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

UNITED STATES OF AMERICA

v.

CHRISTOPHER BRYAN ABLETT,

Defendant.

 

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No. 09-0749 RS

STIPULATION AND PROTECTIVE

ORDER

With the agreement of the parties, and with the consent of the defendant, the Court enters

the following order:

Defendant Christopher Bryan Ablett is charged in Count One of the Indictment with

murder in aid of racketeering, in violation of 18 U.S.C. Section 1959(a)(1), in Count Two with

use/possession of a firearm in a murder, namely the murder charged in Count One, in violation of

18 U.S.C. Section 924(j)(1), and in Count Two with use/possession of a firearm in relation to a

crime of violence, namely the crime charged in Count One, in violation of 18 U.S.C. Section

924(c)(1)(A). Upon request, the Government will provide early disclosure of documents that

*E-Filed 5/20/10*

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STIPULATION AND PROTECTIVE ORDER

[09-0749 RS] 2

constitute prior statements of witnesses, pursuant to 18 U.S.C. Section 3500 (the “Subject

Materials”). The Government requests that disclosure of these materials be subject to the

following restrictions:

1. Production and possession of materials of the Subject Materials be limited only to

Richard Mazer, Esq., and Michael Burt, Esq., counsel for Christopher Bryan Ablett, and that

possession of these materials is limited only to Mssrs. Mazer and Burt and to those who are part

of their respective law offices, including paralegals and investigators;

2. Mssrs. Mazer and Burt’s possession and use of the Subject Materials is only for

the purpose of preparing for and trying the criminal case of Christopher Bryan Ablett, and for no

other purpose;

3. The Subject Materials shall not be distributed or disseminated to anyone else, with

the exception of any appellate or habeas corpus counsel, and shall be used by appellate or habeas

corpus counsel only for the purpose of preparing for the appeal or collateral attack of the case;

and

4. At the end of the trial of Christopher Bryan Ablett, with the sole exception of

providing the Subject Materials to any appellate or habeas corpus counsel, Mssrs. Mazer and

Burt shall return all Subject Materials, and any and all copies of the Subject Materials, to the

Government, which will preserve the materials in case there is need for them in any future

litigation.

STIPULATED:

DATED: May 20, 2010 /s/ 

RICHARD MAZER, ESQ.

Attorney for CHRISTOPHER BRYAN ABLETT

DATED: May18, 2010 /s/ 

MICHAEL BURT, ESQ.

Attorney for CHRISTOPHER BRYAN ABLETT

//

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STIPULATION AND PROTECTIVE ORDER

[09-0749 RS] 3

DATED: May 18, 2010 /s/ 

CHRISTINE Y. WONG

Assistant United States Attorney

IT IS SO ORDERED.

DATED: May __, 2010 

HON. RICHARD SEEBORG

United States District Judge

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