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Nothing in this stipulation is intended to restrict the parties' use or introduction of the Protected Information or the UFED report as evidence at trial or support in motion practice.Ĩ. Defense counsel will ensure that any discovery derived from the UFED report that is left with Defendant is fully redacted of any Protected Information and only contains material relevant to the defense of the federal case.ħ. Defendant shall only be permitted to review the Protected Information or portions of the UFED report relevant to his defense in the presence of defense counsel who shall retain exclusive possession of the Protected Information and the UFED report. attach any Protected Information or the UFED report to any of the pleadings, briefs, or other court filings except to the extent those pleadings, briefs, or filings are filed under seal or properly compliant with LR IC 6-1.Ħ. use the Protected Information or the UFED report for any purpose other than preparing to defend against or prosecute the charges in the Indictment for any purpose or any further superseding indictment arising out of this case or d. allow any other person to read, listen, or otherwise review the Protected Information or the UFED report in this case c.
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make copies for, or allow copies of any kind to be made by any other person of the Protected Information in this case or the UFED report, specifically the full digital download of K.M.'s phone, including all audio, video, photograph, and messaging data contained on the device b. The Covered Individuals shall be advised of the Protective Order, and, without leave of the Court, the Covered Individuals shall not: a. In order to protect the privacy of the individuals referenced in the discovery, the parties intend to restrict access to the following individuals: attorneys for all parties, and any personnel that the attorneys for all parties consider necessary to assist in performing that attorney's duties in the prosecution or defense of this case, including investigators, paralegals, retained experts, support staff, interpreters, and any other individuals specifically authorized by the Court (collectively, the "Covered Individuals").ĥ. This confidential personal identifying information is referred to here as the "Protected Information."Ĥ. and other individuals and also subject them to potential misuse of their identities. The release of such information to the public or third parties not involved in the case could endanger the privacy of K.M. While most of the data contained within the device is irrelevant to the case at hand, it is being turned over to the defense out of an abundance of caution by the government. The UFED Report also contains identifying information including addresses and telephone numbers of persons listed as "contacts" in K.M.'s cellular device. The UFED report therefore contains extensive amount of personal identifying information of the victim, K.M., and other data personal to K.M. The discovery in this case includes a Cellebrite Universal Forensic Extraction Device (UFED) report containing a full digital download of K.M.'s phone, including all audio, video, photograph, and messaging data contained on the device.
The indictment in this case arises out of an arrest stemming from a domestic violence incident and kidnapping of a female victim, K.M., who had been in a domestic relationship with the Defendant. Kirtley filed her notice of appearance on June 11, 2021.ģ. Assistant Federal Public Defender Monique N. The Office of the Federal Publicĭefender was appointed to this case on June 9, 2021. Trial is currently scheduled for December 13, 2021.
The indictment in this case issued on June 2, 2021.Ģ. The parties, by and through the undersigned, respectfully request that the Court issue an order protecting from disclosure to the public, or any third party not directly related to this case, any data, documents, recordings, communications or other tangible things produced by the government's disclosure of a Cellebrite Universal Forensic Extraction Device (UFED) report as discovery in this case.