Government Motion For Protective Order in Raymond "Shrimp Boy" Chow Case

UNITED STATES MOTION FOR PROTECTIVE ORDER
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MELINDA HAAG (CABN 132612)
United States Attorney

J . DOUGLAS WILSON (DCBN 412811)
Chief, Criminal Division

WILLIAM FRENTZEN (LABN 24421)
SUSAN BADGER (CABN 124365)
S. WAQAR HASIB (CABN 234818)
Assistant United States Attorneys

450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: (415) 436-6959
FAX: (415) 436-6753
william.frentzen@usdoj.gov
susan.badger@usdoj.gov
waqar.hasib@usdoj.gov

Attorneys for Plaintiff

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

UNITED STATES OF AMERICA,
Plaintiff,
v.
KWOK CHEUNG CHOW, a/k/a Raymond
Chow, a/k/a Hai J ai, a/k/a Shrimpboy, et.
al.

Defendants.

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No. CR 14-0196 CRB

UNITED STATES MOTION FOR PROTECTIVE
ORDER PURSUANT TO FED.R.CRIM.P. 16(D)

SAN FRANCISCO VENUE

I. INTRODUCTION
The United States and counsel for the defendants have been negotiating the terms of a protective
order that will govern the disclosure of discovery materials in the above-referenced case. To that end,
the parties have circulated a draft protective order to present to the Court. As of the writing of this
Case3:14-cr-00196-CRB Document279 Filed05/08/14 Page1 of 7

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motion, counsel for 24 of the 25
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defendants who have appeared before this Court have stipulated and
signed the protective order.
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However, counsel for the one remaining defendant, Kwok Cheung CHOW,
has indicated that he will not sign on. Accordingly, the United States hereby moves the Court to
exercise its discretion and authority under Rule 16(d)(1) of the Federal Rules of Criminal Procedure and
issue the protective order as is, requiring all parties to comply: the United States, the 24 defendants who
have signed on already, and the one, CHOW, who has refused. As discussed in further detail below,
there is ample justification for this order, given the nature and scope of the discovery materials at issue,
and given the Courts broad discretion under Rule 16(d)(1).
II. FACTS
On April 3, 2014, the defendants were charged in a 50-count indictment alleging, among other
offenses, money laundering, trafficking in narcotics, firearms, and contraband cigarettes, murder for
hire, and honest services fraud. Docket No. 113. On April 10, 2014, the United States filed a statement
regarding discovery, advising the defendants that it intended to seek a protective order before releasing
any discovery materials to them. Docket No. 175. The defendants designated four of their attorneys to
form a working group to negotiate the terms of said protective order. Counsel for the United States and
the defendants designated working group communicated on numerous occasions by telephone, e-mail,
and in person, including on one occasion under the supervision of the Honorable Magistrate J udge
J oseph C. Spero. As a result, by approximately April 25, 2014, counsel for the United States and the
working group were able to agree on language for a draft protective order to present to the Court. The
working group then circulated that draft to counsel for the remaining defendants.
Counsel for the United States has since received a signed stipulation and protective order from
attorneys for all but two defendants who have appeared before this Court. The first is a defendant whose
attorney has advised the United States of a likely substitution of counsel in the near future, and as such is
not in a position to stipulate to the protective order. The second, the attorney for defendant Kwok

1
The Court will recall that in fact, 26 defendants have made appearances in this case. However,
as discussed in further detail below, the attorney for one defendant has advised the United States of a
likely substitution of counsel in the near future. Accordingly, until new counsel is identified, the United
States does not count that defendant among these numbers.
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The defendants assigned discovery coordinator has also signed on.

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Cheung CHOW, has advised that he does not intend to stipulate to the protective order, and has asked
the United States to prepare alternative arrangements to make discovery available to him.
III. ARGUMENT
The indictment in this case is the result of a multi-year investigation by the Federal Bureau of
Investigation (FBI) into organized crime and public corruption in and around the San Francisco Bay
Area, using undercover agents and wiretaps, among other investigative techniques, to infiltrate
organizations allegedly engaging in illegal activities. Over the course of the investigation, agents have
amassed large amounts of potential evidence, including audio recordings of defendants meeting with
undercover agents, video surveillance, wiretapped communications, consensually-recorded telephone
calls, and emails, among other materials. Most of these materials are held by the FBI in digital form; the
total amount of digital materials is expected to measure several terabytes (TB) worth of information.
Many of these materials are disclosable to the defendants under Rule 16 of the Federal Rules of
Criminal Procedure. Many, however, are not, because they arguably do not fall within the scope of Rule
16 or any other basis for discovery. Moreover, many of the materials contain sensitive information
which the United States would otherwise redact or limit from disclosure. For example, of utmost
concern to the United States are sensitive materials that, if improperly disclosed, could be used to expose
the true identities of undercover employees involved in the investigation, thereby placing them in harms
way. Of equal concern are those sensitive materials that, if improperly disclosed, could be used to
identify individuals who have not yet been charged by the United States, but whose ongoing criminal
activities are still under investigation. In addition, there are sensitive materials identifying numerous
individuals who are not believed to have engaged in any criminal activities, but who were nonetheless
captured on FBI surveillance or documented in FBI reports, for example after being introduced by
charged defendants to undercover agents. Such materials, if improperly disclosed, could be used to
besmirch these otherwise innocent individuals. Finally, there are sensitive materials that, if improperly
disclosed, could conceivably raise witness safety issues.
Parsing out and redacting the materials described above would be an enormous, time-consuming,
and expensive task for the United States to undertake.
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As just one example of the difficulties involved,

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Indeed, this Court recognized as much during a status conference on April 17, 2014, noting that

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during pertinent and relevant conversations intercepted on wiretaps, charged defendants and named
interceptees often mentioned the names of third parties, including public officials and public figures.
These comments and references sometimes arose in a context that suggested possible wrongdoing, but
the investigation never developed evidence in that regard. It would be a herculean task, if not
impossible, to extract such comments and references from the rest of the discovery materials, as they are
embedded in many, many intercepted and otherwise pertinent conversations.
Instead, in the interests of efficiency and maximizing both government and defense resources,
the United States offered to turn over the vast majority of the materials in its possession, regardless of
whether they are discoverable under Rule 16 or otherwise, with the caveat that the materials be subject
to a stipulated protective order.
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As mentioned briefly above, after a lengthy negotiation process, nearly
all of the defendants who have appeared before this Court have stipulated and signed on to a protective
order, through their attorneys, with one notable exception: Kwong Cheung CHOW, whose attorney has
advised that he will not sign it.
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The United States now asks the Court to exercise its discretion and
authority under Rule 16(d)(1) to issue the stipulation and order, attached as Exhibit 1, as is
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, requiring all
parties to comply: the United States, the 24 defendants who have signed on already, and the one,
CHOW, who has refused.
Rule 16(d)(1) grants the Court broad discretion to issue protective orders to deny, restrict, or
defer discovery or inspection for good cause. Fed. R. Crim. Pr. 16(d). The Supreme Court has

it was mindful of the complexity of the investigation, and of the difficulty of culling out discrete
categories of materials that fell within the scope of Rule 16.
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Indeed, the United States has already started producing materials to the defendants discovery
coordinator, who has agreed to keep them in escrow until issues regarding the protective order are
resolved.
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See fn. 1, supra. The attorney for one other defendant has also declined to sign the protective
order, but not because of any substantive disagreements with it. Rather, that attorney has indicated to
the United States that there will likely be a substitution of counsel in the near future.
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As is, with the following minor edits to address the issues raised in this motion: 1) The United
States proposes removing the first two clauses of the first sentence of the stipulation, which currently
read With the agreement of the parties, and with the consent of the defendants, and simply beginning
that sentence with the clause The Court enters the following order; and 2) The United States proposes
removing the last line of the stipulation, which reads IT IS SO STIPULATED, and removing the
signature lines for all parties, leaving only the signature line for the Court. In accordance with local
practice, the United States will submit both a .pdf version and word processing version to the Court so
that any such edits can be made.

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elaborated that the trial court can and should, where appropriate, place a defendant and his counsel
under enforceable orders against unwarranted disclosure of the materials which they may be entitled to
inspect. Alderman v. United States, 394 U.S. 165, 185 (1969). Analysis in the Ninth Circuit of Rule
16(d) has generally been limited to cases involving national security, which is by and large not an issue
in this case, and cases involving witness safety, which is somewhat of an issue in this case, but not a
paramount one. See, e.g., United States v. Sedaghaty, 728 F.3d 885, 904-09 (9th Cir. 2013)(discussing
use of Classified Information Procedures Act (CIPA) in conjunction with Rule 16(d)(1)); United
States v. Fort, 472 F.3d 1106, 1130 (9th Cir. 2007)(noting that Rule 16(d)(1) is the appropriate vehicle
for a protective order in cases involving witness safety). Other courts, however, have squarely
addressed and approved of the use of protective orders in cases similar to the one here. See, e.g., United
States v. Smith, __ F.Supp.2d__, 2013 WL 6576791 (S.D.N.Y. 2013); United States v. Bulger, 283
F.R.D. 46 (D.Mass. 2012). The Smith case from the Southern District of New York is particularly
instructive. There, several defendants were charged with extortion, bribery, and fraud in connection
with a public corruption investigation involving wiretaps. There, as here, the government sought a
blanket protective order limiting dissemination of a broad range of materials that it had produced as part
of discovery. Id. at *11. There, as here, the government argued that the protective order was necessary,
partly to protect otherwise innocent third parties whose interests might be jeopardized by being
associated with the defendants, and partly to protect the integrity of ongoing investigations. Id.
With respect to the governments first argument, the Smith court concluded good cause for a
protective order could exist if the government could identify for the court, ex parte, specific innocent
third parties whose reputations would be damaged by improper disclosure of discovery materials. Smith,
at 15-16. In doing so, the court noted the unfairness of [innocent third parties] being stigmatized from
sensationalized and potentially out-of-context insinuations of wrongdoing, combined with the inability
of these third parties to clear their names at trial. Id. at *13. With respect to the governments second
argument, the court concluded that a protective order was appropriate where public disclosure of
certain materials might officially reveal the sources and methods law enforcement officials have used,
and will continue to use, to investigate other criminal conduct related to the publicly filed charges .
Id. at *17.

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The grounds upon which the government sought a protective order in Smith are remarkably
similar to the grounds raised here. Accordingly, although Smith is of course not binding on this Court,
its reasoning is instructive, and the United States urges this Court to reach a similar outcome. To that
end, the draft protective order stipulated and agreed to by the United States and 24 defendants, minus
CHOW, is attached as Exhibit 1. The United States urges the Court to issue it as is (with the minor edits
described above at footnote 6), and as to all defendants, including CHOW.
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Given the refusal by defendant CHOW to sign onto the stipulation, the Court may be tempted to
fashion a separate arrangement for CHOW to obtain Rule 16 materials. The United States urges the
Court to resist this temptation. At a bare minimum, to accommodate CHOW the United States would
need to engage in an extremely labor-intensive review of multiple terabytes of digital information to
identify those materials to which CHOW is entitled under Rule 16, then separate those materials from
the rest and begin an equally labor-intensive redaction process. On top of that, the United States would
have to set up a secure location inside the courthouse so that CHOWs attorneys can view the materials,
and devote government employees to staff that location whenever CHOWs attorneys are present to
ensure that the materials remain secure (the same government employees, incidentally, who are
otherwise currently occupied preparing disclosure of discovery materials pursuant to the protective
order.)
The Federal Rules of Criminal Procedure are to be interpreted to secure simplicity in procedure
and fairness in administration, and to eliminate unjustifiable expense and delay. Fed. R. Crim. P. 2.
The United States and, to their credit, counsel for 25 defendants have reached an agreement that allows
for straightforward, prompt, efficient and cost-effective disclosure of Rule 16 discovery while at the
same time protecting the United States very tangible and real interests in preventing unauthorized leaks
of discovery materials. CHOW has yet to offer the United States any reason or justification for not
stipulating to the protective order. Carving out an exception for one recalcitrant defendant would fly in

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The Smith court was reluctant to issue a protective order absent a showing of good cause by the
government. In the instant case, the Court here has already suggested, at least tentatively, during a
status conference on April 17, 2014, that based on its familiarity with the investigation from its role
authorizing wiretaps, good cause exists to issue a protective order. If the Court needs further
information in this regard, upon request and in accordance with Rule 16(d)(1), the United States will
submit to the Court an ex parte written statement supplementing this motion.

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the face of the clear instructions of Rule 2.
IV. CONCLUSION
For the reasons discussed above, the United States respectfully asks the Court to exercise its
discretion and authority under Rule 16(d)(1) of the Federal Rules of Criminal Procedure and issue the
protective order as is (with the minor edits described above at footnote 6), requiring all parties to
comply: the United States, the 24 defendants who have stipulated to the protective order, and the one,
CHOW, who has not.
DATED: May 8, 2014 Respectfully submitted,
MELINDA HAAG
/s/
WILLIAM FRENTZEN
SUSAN BADGER
S. WAQAR HASIB


EXHIBIT 1

Case3:14-cr-00196-CRB Document279-1 Filed05/08/14 Page1 of 11

STIPULATED AND [PROPOSED] PROTECTIVE ORDER
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MELINDA HAAG (CABN 132612)

J . DOUGLAS WILSON (DCBN 412811)
Chief, Criminal Division

WILLIAM FRENTZEN (LABN 24421)
SUSAN BADGER (CABN 124365)
S. WAQAR HASIB (CABN 234818)

450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: (415) 436-6959
FAX: (415) 436-6753
william.frentzen@usdoj.gov
susan.badger@usdoj.gov
waqar.hasib@usdoj.gov

Attorneys for Plaintiff

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

UNITED STATES OF AMERICA,
Plaintiff,
v.
KWOK CHEUNG CHOW, a/k/a Raymond
Chow, a/k/a Hai J ai, a/k/a Shrimpboy;
LELAND YEE, a/k/a Senator Leland Yee;
GEORGE NIEH, a/k/a Heng Nieh;
KEITH J ACKSON;
KEVIN SIU, a/k/a Dragon Tin Loong Siu;
ALAN CHIU, a/k/a Alan Shiu;
KONGPHET CHANTHAVONG, a/k/a J oe,
a/k/a Fat J oe;
XIAO CHENG MEI, a/k/a Michael Mei;
BRANDON J AMELLE J ACKSON;
MARLON DARRELL SULLIVAN;
RINN ROEUN;
ANDY LI, a/k/a Andy Man Lai Li;
LESLIE YUN, a/k/a Leslie Yuncheung;
YAT WA PAU, a/k/a J ames Pau;
J ANE MIAO XHEN LIANG;
TINA YAO GUI LIANG;
BRYAN TILTON;
HUAN MING MA, a/k/a Ming Ma, a/k/a
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No. CR 14-0196 CRB

STIPULATED AND [PROPOSED]
PROTECTIVE ORDER

[DRAFT]

SAN FRANCISCO VENUE


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Baak Ban;
HON KEUNG SO, a/k/a Hon So;
NORGE MASTRANGELO;
ALBERT NHINGSAVATH;
SERGE GEE;
XIU YING LING LIANG, a/k/a Elaine
Liang;
GARY KWONG YIU CHEN, a/k/a Gary
Chen, a/k/a J immy, a/k/a David;
ANTHONY J OHN LAI, a/k/a AJ ;
TONG ZAO ZHANG;
ZHANGHAO WU, a/k/a J ason;
BARRY BLACKWELL HOUSE, a/k/a Barry
Black;
WILSON SY LIM, a/k/a Dr. Lim,

Defendants.

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With the agreement of the parties, and with the consent of defendants, the Court enters the
following Protective Order:
Pursuant to the defendants requests, the government will be providing, directly as well as
through a copy vendor, copies of documents, recordings, and other materials (the SUBJ ECT
MATERIALS), marked with identifying Bates numbers, in lieu of making them available for review as
follows and under the conditions of this Protective Order:
1. Pursuant to its discovery obligations, the government intends to produce discovery
including but not limited to Rule 16 and wiretap information. All the material that the government
produces to the defense in the above-captioned case pursuant to its discovery obligations will be
designated as SUBJ ECT MATERIALS. Defendants are signing this Protective Order for purposes of
expediting discovery and are doing so with a reservation of rights to dispute the governments
designation of specific materials as SUBJ ECT MATERIALS that should be subject to the terms of this
Protective Order. Should any defendant disagree with the governments designation of any materials as
SUBJ ECT MATERIALS, the defendant must initially meet and confer with the government to resolve
the dispute if possible. If after meeting and conferring with the government the defendant disagrees
with the governments determination as to the characterization of the material(s), the defendants next

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avenue for resolution is to notify the Court and seek a judicial determination of whether the specific
materials at issue should be designated as SUBJ ECT MATERIALS and continue to be subject to the
terms of this Protective Order.
2. Except when being actively examined, transferred as permitted by this Protected Order,
or used for the purpose of the preparation of the defense of defendants, the SUBJ ECT MATERIALS
shall be maintained in safe and secure places in defense counsels office(s) and/or secured in a password
protected electronic format, which shall be accessible only to defense counsel, members and employees
of his or her law firm who are working with him or her to prepare defendants defense, the defendants,
retained investigators and experts, and others identified in Paragraphs 3. Defense counsel, members and
employees of his or her law firm, the defendants, and the investigator(s) shall not permit any person
access of any kind to the SUBJ ECT MATERIALS except as set forth below.
3. The following individuals may obtain copies of the SUBJ ECT MATERIALS for the sole
purpose of preparing the defense of defendants in this action and for no other purpose:
a) Counsel for defendants;
b) Members and employees of defense counsels law office who are assisting with
the preparation of defendants defense;
c) Court appointed discovery coordinator;
d) Defendants, as follows:
i. In the presence of defense counsel or another authorized person listed in
this paragraph;
ii. In a room at defense counsels offices under the following conditions: the
SUBJ ECT MATERIALS will be available by paper copy or on a
computer or electronic media that will lack Internet access and lack the
ability to copy the SUBJ ECT MATERIALS onto a disk, a drive, or other
media; no telephones or cameras will be permitted in the room while the
defendant is reviewing the SUBJ ECT MATERIALS; a member of
defense counsels staff will supervise the review but need not be present

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in the room during the review; and defense counsel will take reasonable
steps to comply with this provision.
iii. For defendants represented by defense counsel appointed under the
Criminal J ustice Act, SUBJ ECT MATERIALS might be provided for
review in space located at the federal building at 450 Golden Gate
Avenue in San Francisco under procedures to be determined.
iv. Defendants may not take or maintain the SUBJ ECT MATERIALS or
copies thereof outside of the parameters set forth above.
e) Potential witnesses, but only in the presence of defense counsel or another
authorized person listed in this Protective Order, (potential witnesses may not take
or maintain the SUBJ ECT MATERIALS or copies thereof);
f) Investigators, experts, paralegals and law clerks retained to assist in the defense of
this matter;
g) Vendors or personnel whose services are employed to copy, transcribe, use,
prepare, or translate SUBJ ECT MATERIALS.
4. A copy of this Order shall be maintained by defense counsel at all times in the principal
place where the SUBJ ECT MATERIALS are maintained.
5. All individuals described in Paragraph 3, other than defense counsel (and employees of
his/her office) and potential witnesses, who receive access to the SUBJ ECT MATERIALS, prior to
receiving access to the materials, shall sign a copy of this Order acknowledging that:
a) they have reviewed the Order and are bound by its terms;
b) they understand its contents;
c) they agree that they will only access the SUBJ ECT MATERIALS and
information for the purposes of preparing a defense for defendant;
d) they understand that failure to abide by this Order may result in sanctions by this
Court.
e) they agree that they will not give the SUBJ ECT MATERIALS to any other

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individuals.
Counsel for the parties shall maintain in their files signed copies of the Order to be made available upon
request under seal to the Court.
6. Defense counsel may provide copies of SUBJ ECT MATERIALS to experts and/or
investigators working for defense counsel, but only in accordance with the procedures described below.
The experts and investigators who receive SUBJ ECT MATERIALS must maintain them in a safe and
secure place in their office(s), which shall be accessible only to them, and/or secured in a password
protected electronic format, except when the SUBJ ECT MATERIALS are being actively examined or
used for the purpose of the preparation of the defense or are being transferred as permitted by this
Protective Order.
7. Counsel for defendants shall maintain a log of SUBJ ECT MATERIALS provided to any
experts and/or investigators, which log shall include the Bates numbers of documents provided and the
names of the person(s) receiving the materials. The logs will be maintained in a secure manner. If (1)
upon a showing of good cause to believe that there was a breach of this Protective Order and that a copy
of the log should be requested from specified defense counsel and (2) after specified defense counsel
receives notice of the reason(s) the log is being requested and has an opportunity to be heard by the
Court on the matter, the Court may order the specified defense counsel to produce the log to the Court.
In that event, the directed defense counsel shall submit a copy of the log to the Court ex parte and under
seal and waives any objection based on the work-product doctrine to producing a copy of the log to the
Court in this manner. Before the Court discloses the log to the government or to any third party, defense
counsel shall receive notice of the potential disclosure and shall have an opportunity to be heard by the
Court and to object to any such disclosure; in that event, defendant and defense counsel reserve all rights
to object to disclosure of the log to the government or to any third-party, including, without limitation,
objections based on the work-product doctrine.
8. Counsel for the defendants, within thirty calendar days of the conclusion of the above-
captioned proceedings before the Court, shall retrieve all copies of the SUBJ ECT MATERIALS
provided to anyone pursuant to this Order. Counsel may then destroy copies which counsel deems

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unnecessary to preserve, and maintain or return to the government the balance in a manner consistent
with this Order.
9. No other person may be allowed to examine the SUBJ ECT MATERIALS without further
order of the Court. Examination of the SUBJ ECT MATERIALS shall be done in a secure environment
which will not expose the materials to other individuals not authorized to access the SUBJ ECT
MATERIALS.
10. The SUBJ ECT MATERIALS may be duplicated to the extent necessary to prepare the
defense of this matter. Any duplicates will be treated as originals in accordance with this Order.
11. Notwithstanding the foregoing, SUBJ ECT MATERIALS, including audio recordings,
can be reviewed by the defendants who are detained outside the presence of counsel under conditions to
be determined and described in an amendment to this Protective Order.
12. The protocol for SUBJ ECT MATERIALS set forth in paragraph 11 does not bind any jail
in which the defendants may be housed to accepting the protocol. Rather, the protocol set forth in
paragraph 11 is merely an agreement between the government and the defendants only. The defendants
shall separately confer with the jail in which they are housed regarding whether and how the jail will
maintain the SUBJ ECT MATERIALS. Nothing in this stipulation is intended to divest jail officials of
their discretion and authority in operating the jail and maintaining the safety and security of the jail.
13. The government shall request that the defense team return copies of the SUBJ ECT
MATERIALS to the United States thirty calendar days after any one of the following events, whichever
occurs latest in time: dismissal of all charges against the defendant; the defendants acquittal by court or
jury; or the conclusion of any direct appeal, including the time required for counsel to comply with
Ninth Circuit Rule 4-1(e). Defense counsel shall comply with the governments request. Defense
counsel, however, may retain for its records one copy of the SUBJ ECT MATERIALS, which shall be
kept in a secure location. Defense counsel need not disclose to the government any work product that
incorporates any SUBJ ECT MATERIALS.
14. After the conclusion of proceedings in the district court or any direct appeal in the above-
captioned case, including the time required for counsel to comply with Ninth Circuit Rule 4-1(e), the

CR 14-0196 CRB 7

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government will maintain a copy of the SUBJ ECT MATERIALS. The government will maintain the
SUBJ ECT MATERIALS until the time period for filing a motion pursuant to 28 U.S.C. 2255 has
expired. After the statutory time period for filing such a motion has expired, the government may
destroy the SUBJ ECT MATERIALS. In the event defendant is represented by counsel and files a
motion pursuant to 28 U.S.C. 2255, the government will provide that counsel with a copy of the
SUBJ ECT MATERIALS under the same restrictions as trial and direct appeal defense counsel.
Defendants attorney in any action under 28 U.S.C. 2255 shall return the same materials thirty
calendar days after the district courts ruling on the motion or thirty calendar days after the conclusion of
any direct appeal of the district courts denial of the motion, whichever is later.
15. This Protective Order does not limit or modify the parties rights to use the SUBJ ECT
MATERIALS in judicial proceedings in this action, including in any trial or pretrial matters before the
Court, using appropriate procedures to protect the safety and security of third parties when necessary.
Any SUBJ ECT MATERIALS that reveal the images or the true identities of any federal undercover
agents or confidential human sources shall be filed under seal.
IT IS SO STIPULATED.

Dated: ____________ MELINDA HAAG

By: ____________________
WILLIAM FRENTZEN
SUSAN BADGER
S. WAQAR HASIB

Dated: ______________
J . TONY SERRA
Counsel for defendant Kwok Cheung
CHOW
Dated: ______________
J AMES LASSART
Counsel for defendant Leland Yin
YEE


CR 14-0196 CRB 8

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Dated:_______
GILBERT EISENBERG
Counsel for defendant George NIEH
Dated: ______________
J AMES BROSNAHAN
Counsel for defendant Keith
J ACKSON
Dated: ______________
ROBERT WAGGENER
Counsel for defendant Kevin SIU
Dated: ______________
SARA ELLEN RIEF
Counsel for defendant Alan CHIU
Dated: ______________
CLAIRE LEARY
Counsel for defendant Kongphet
CHANTHAVONG
Dated: ______________
DORON WEINBERG
Counsel for defendant Xiao Cheng
MEI
Dated: ______________
TONY TAMBURELLO
Counsel for defendant Brandon
J amelle J ACKSON
Dated: ______________
KURT KEVIN ROBINSON
Counsel for defendant Marlon
Darrell SULLIVAN
Dated: ______________
GARRICK LEW
Counsel for defendant Rinn ROEUN
Dated: ______________
WINSTON CHAN
Counsel for defendant Andy LI
Dated: ______________
DENNIS RIORDAN
Counsel for defendant Leslie YUN


CR 14-0196 CRB 9

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Dated: ______________
TERESA CAFFESE
Counsel for defendant Yat Wa PAU
Dated: ______________
J AI GOHEL
Counsel for defendant J ane Miao
Xhen LIANG
Dated: ______________
MICHAEL STEPANIAN
Counsel for defendant Tina Yao Gui
LIANG
Dated: ______________
HARRIS TABACK
Counsel for defendant Bryant
TILTON
Dated: ______________
ROGER PATTON
Counsel for defendant Huan Ming
MA

Dated: ______________
EDWIN PRATHER
Counsel for defendant Hon Keung
SO
Dated: ______________
J ULIA J AYNE
Counsel for defendant Norge
MASTRANGELO
Dated: ______________
RANDY KNOX
Counsel for defendant Albert
NHINGSAVATH
Dated: ______________
[NAME]
Counsel for defendant Serge GEE
Dated: ______________
NICOLE GIACINTI
Counsel for defendant Xiu Ying
Ling LIANG
Dated: ______________
J ONATHAN PIPER
Counsel for defendant Gary Kwong
Yiu CHEN


CR 14-0196 CRB 10

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Dated: ______________
CHRISTOPHER CANNON
Counsel for defendant Anthony J ohn
LAI
Dated: ______________
[NAME]
Counsel for defendant Tong Zao
ZHANG
Dated: ______________
[NAME]
Counsel for defendant Zhanghao
WU
Dated: ______________
ELIZABETH FALK
Counsel for defendant Barry
Blackwell HOUSE
Dated: ______________
J ONATHAN MCDOUGALL
Counsel for defendant Wilson Sy
LIM

IT IS SO ORDERED.

Dated: ____________
HON. CHARLES R. BREYER
United States District J udge

Government Motion For Protective Order in Raymond "Shrimp Boy" Chow Case

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Government Motion For Protective Order in Raymond "Shrimp Boy" Chow Case

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UNITED STATES MOTION FOR PROTECTIVE ORDER

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