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United States v. Amado-Ortiz

United States District Court, S.D. New York

January 14, 2020

UNITED STATES OF AMERICA
v.
Ruben Amado-Ortiz, a/k/a "Venegas," Defendant.

          Geoffrey S. Berman United States Attorney

          Sarah Mortazavi Cecilia E. Vogel Assistant United States Attorney

          Samuel Gregory, Esq. II Counsel for Ruben Amado-Ortiz, a/k/a "Venegas,"

          [PROPOSED] PROTECTIVE ORDER

          Hon. Jesse M. Furman United States District Judge

         Upon the application of the United States of America, with the consent of the undersigned counsel, and the defendant having requested discovery under Fed. R. Crim. P. 16, the Court hereby finds and orders as follows:

         1. Disclosure Material.

         The Government will make disclosure to the defendant documents, objects and information, including electronically stored information ("ESI"), pursuant to Federal Rule of Criminal Procedure 16, 18 U.S.C. § 3500, and the Government's general obligation to produce exculpatory and impeachment material in criminal cases, all of which will be referred to herein as "disclosure material."

         2. Sensitive Disclosure Material.

         The Government's disclosure material includes the contents of cellphones, which contain material that affects the privacy and confidentiality of individuals (e.g., communications and photographs personal in nature). Accordingly, the contents of all cellphones produced in this matter are deemed "Sensitive Disclosure Material," with the exception that the contents of the defendant's own cellphone is not deemed "Sensitive Disclosure Material."

         3. Facilitation of Discovery.

         The entry of a protective order in this case will permit the Government to produce expeditiously the disclosure material without further litigation or the need for redaction. It will also afford the defense prompt access to those materials, in unredacted form, which will facilitate the preparation of the defense.

         4. Good Cause.

         There is good cause for entry of the protective order set forth herein.

         5. Restrictions on Sensitive ...


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