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No.: CR 3-05-70262 JL

STIP. & [PROPOSED] PROT. ORDER RE COMPUTER

DISCOVERY AS TO DEFS STUART, LANGE & DOUGLAS

KEVIN V. RYAN (CSBN 118321)

United States Attorney

EUMI L. CHOI (WVBN 0722)

Chief, Criminal Division

MONICA FERNANDEZ (CSBN 168216)

Assistant United States Attorney

450 Golden Gate Avenue, Box 36055

San Francisco, California 94102-3495

Telephone: (415) 436-7065

FAX: (415) 436-7234

E-mail: Monica.L.Fernandez@usdoj.gov

Attorneys for Plaintiff

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v.

TIFFANY STUART, aka Jane Doe,

JENNIFER LANGE, and

BRANDY DOUGLAS,

Defendants.

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No.: CR 3-05-70262 JL

STIPULATION AND [PROPOSED]

PROTECTIVE ORDER REGARDING

COMPUTER DISCOVERY AS TO

DEFENDANTS STUART, LANGE AND

DOUGLAS

The United States, through its counsel of record, and the defendants, through their

counsel of record, hereby agree and stipulate that the government will provide computer

discovery (consisting of seized computer evidence) on the following conditions:

The computer discovery produced in this matter is deemed Protected Material.

Possession of copies of the Protected Material is limited to the defendants, their attorneys of

Case 3:05-mj-70262-MAG Document 68 Filed 10/14/05 Page 1 of 3
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No.: CR 3-05-70262 JL

STIP. & [PROPOSED] PROT. ORDER RE COMPUTER

DISCOVERY AS TO DEFS STUART, LANGE & DOUGLAS 2

record, and investigators, paralegals, law clerks, translators, interpreters, experts and assistants

for the attorneys of record (hereinafter collectively referred to as "members of the defense team").

The defendants, their attorneys of record, and members of the defense team acknowledge

that providing copies of the Protected Material to other persons is prohibited, and agree not to

duplicate or provide copies of the Protected Material to other persons. The defendants, their

attorneys of record, and members of the defense team may show Protected Material to witnesses

or prospective witnesses in conjunction with their defense of the defendants in this case. The

defendants, their attorneys of record, and members of the defense team further acknowledge that

they are prohibited from using the Protected Material for any purpose other than defending the

defendant in the above-captioned matter. Any violation of these prohibitions constitutes a

violation of the Protective Order. Further, the attorneys of record agree that prior to

disseminating any copies of the Protected Material to members of the defense team, they will

provide a copy of this Protective Order to members of the defense team.

Notwithstanding efforts taken by the government to redact personal information of

witnesses from the discovery provided to the defense (such as date of birth, social security

numbers, addresses, phone numbers, etc.), defense counsel, the defendants and members of the

defense team agree that, should any such information be found during their review of this

material, they will not provide that personal information in any form – whether in verbal, written

or electronic format – to any third party, for any reason whatsoever.

2 Nontermination

The provisions of this Order shall not terminate at the conclusion of this prosecution but

only upon further order of this Court. Within 30 days of a verdict or guilty plea, the defendants’

attorneys of record shall return all copies of any Protected Material (including all copies provided

to the defendants, their attorneys of record, and members of the defense team) to the United

States Attorney’s Office for the Northern District of California.

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No.: CR 3-05-70262 JL

STIP. & [PROPOSED] PROT. ORDER RE COMPUTER

DISCOVERY AS TO DEFS STUART, LANGE & DOUGLAS 3

IT IS SO STIPULATED.

DATED: October 14, 2005 /s/ Monica Fernandez

MONICA FERNANDEZ

Assistant United States Attorney

Counsel for the United States

DATED: October 3, 2005 /s/ Josh Cohen

JOSH COHEN

Counsel for Defendant STUART

DATED: October 3, 2005 /s/ Suzanne Luban

SUZANNE LUBAN

Counsel for Defendant LANGE

DATED: October 13, 2005 /s/ Geoffrey Rotwein

GEOFFREY ROTWEIN

Counsel for Defendant DOUGLAS

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.

DATED: October __, 2005 ___________________________________

HONORABLE JAMES LARSON

UNITED STATES MAGISTRATE JUDGE

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge James Larson

Case 3:05-mj-70262-MAG Document 68 Filed 10/14/05 Page 3 of 3