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UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

UNITED STATES OF AMERICA, 

Plaintiff, 

CRIMINAL NO. 15-cr-20382 

v. 

HONORABLE VICTORIA A. ROBERTS 

D-1 PAUL NICOLETTI, 

Defendant. 

 / 

STIPULATION FOR A PROTECTIVE ORDER 

REGARDING PRODUCTION OF FINANCIAL, BANKING, 

TAX AND OTHER RECORDS CONTAINING PERSONALLY 

IDENTIFIABLE AND OTHER SENSITIVE INFORMATION 

Plaintiff, the United States of America, by its attorneys, Barbara L. 

McQuade, United States Attorney, and Craig A. Weier, Assistant United States 

Attorney, both for the Eastern District of Michigan, together with D-1 PAUL 

NICOLETTI, through his attorney, John Minock, Esq., hereby stipulate to the entry 

of a Protective Order with respect to the production of financial, banking and other 

records containing personally identifiable information [PII] and other sensitive 

information in this criminal proceeding. 

1. The indictment in this case includes charges of Conspiracy to Commit 

Bank Fraud and Bank Fraud; 

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2. During the course of the underlying investigation, the United States 

obtained tax, financial and banking records as well as other documents 

containing personally identifiable information and other sensitive 

information, consisting of thousands of pages of materials relating to parties 

and non-parties. 

Therefore, the government and the defendants stipulate that: 

3. Given the nature of the underlying charges, in order to provide 

meaningful discovery of the subject materials, the defendant will need to 

examine those materials in their original form, without redactions. 

4. In addition, given the volume of discovery materials, the review and 

redaction of information from individual documents would be unnecessarily 

burdensome and would result in significant delays in making the subject 

materials available to defendant. 

5. Therefore, the parties agree that a protective order will allow for the 

subject information to be produced in its original form and further agree 

that the documents produced pursuant to the protective order will only be 

disclosed to, and reviewed by, the defendant, his counsel of record, and 

investigators and experts retained by defense counsel for consultation, as 

well as defense counsel=s support staff. No person shall provide or 

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disseminate those materials or the information contained in those 

materials to any party not specifically described in the protective order 

and any unauthorized disclosure would constitute a violation of the 

Court=s Order. 

6. Any filing that includes or refer to any of the subject records, which 

filing contain social security numbers, tax identification numbers, dates of 

birth, the names of individuals known to be minors, financial accounts or 

home addresses of parties or non-parties, shall be filed in compliance with 

Rule 49.1 of the Federal Rules of Criminal Procedure and the Electronic 

Filing Policies and Procedures of the United States District Court for the 

Eastern District of Michigan. 

WHEREFORE, for all the foregoing reasons, the parties respectfully request 

that this Court enter a Protective Order allowing the government to produce 

unredacted copies of financial, banking and other records containing personally 

identifiable information [PII] and other sensitive information to defendant, through 

his counsel of record in this proceeding, and restricting the use of the documents 

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and information as provided above. 

So stipulated and respectfully submitted, 

BARBARA L. McQUADE 

United States Attorney 

s/CRAIG A. WEIER (P33261) 

Assistant United States Attorney 

211 W. Fort Street, Suite 2001 

Detroit, MI 48226 

Phone: (313) 226-9678 

E-Mail: craig.weier@usdoj.gov 

s/JOHN R. MINOCK, ESQ. (P24626) 

 Attorney for D-1 Paul Nicoletti 

 Cramer Minock & Sweeney PLC 

339 E Liberty St Ste 200 

Ann Arbor, MI 48104-2258 

Phone: (734) 668-2200 

 E-Mail: jminock@cramerminock.com 

IT IS SO ORDERED. 

___________________________

VICTORIA A. ROBERTS 

UNITED STATES DISTRICT JUDGE

EASTERN DISTRICT OF MICHIGAN 

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