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

UNITED STATES MOTION FOR PROTECTIVE ORDER CR 14-0196 CRB 1

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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 [email protected]

[email protected] [email protected] 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 Jai, a/k/a Shrimpboy, et. al. Defendants.

) ) ) ) ) ) ) ) ) ) ) ) )

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 251 defendants who have appeared before this Court have stipulated and

signed the protective order.2 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 Judge

Joseph 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.

2 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.3 As just one example of the difficulties involved,

3 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.4 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.5 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 is6, 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.

4 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.

5 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.

6 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.7

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

7 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 United States Attorney

/s/WILLIAM FRENTZEN SUSAN BADGER S. WAQAR HASIB Assistant United States Attorneys


EXHIBIT 1

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

STIPULATED AND [PROPOSED] PROTECTIVE ORDER CR 14-0196 CRB 1

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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 [email protected]

[email protected] [email protected] 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 Jai, a/k/a Shrimpboy; LELAND YEE, a/k/a Senator Leland Yee; GEORGE NIEH, a/k/a Heng Nieh; KEITH JACKSON; KEVIN SIU, a/k/a Dragon Tin Loong Siu; ALAN CHIU, a/k/a Alan Shiu; KONGPHET CHANTHAVONG, a/k/a Joe, a/k/a Fat Joe; XIAO CHENG MEI, a/k/a Michael Mei; BRANDON JAMELLE JACKSON; 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 James Pau; JANE MIAO XHEN LIANG; TINA YAO GUI LIANG; BRYAN TILTON; HUAN MING MA, a/k/a Ming Ma, a/k/a

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

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 Jimmy, a/k/a David; ANTHONY JOHN LAI, a/k/a AJ; TONG ZAO ZHANG; ZHANGHAO WU, a/k/a Jason; BARRY BLACKWELL HOUSE, a/k/a Barry Black; WILSON SY LIM, a/k/a Dr. Lim, Defendants.

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

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 SUBJECT

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 SUBJECT 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 SUBJECT MATERIALS that should be subject to the terms of this

Protective Order. Should any defendant disagree with the governments designation of any materials as

SUBJECT 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 SUBJECT 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 SUBJECT 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 SUBJECT MATERIALS except as set forth below.

3. The following individuals may obtain copies of the SUBJECT 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

SUBJECT 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 SUBJECT 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 SUBJECT 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 Justice Act, SUBJECT 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 SUBJECT 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 SUBJECT 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 SUBJECT MATERIALS.

4. A copy of this Order shall be maintained by defense counsel at all times in the principal

place where the SUBJECT 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 SUBJECT 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 SUBJECT 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 SUBJECT 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 SUBJECT 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 SUBJECT 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 SUBJECT 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 SUBJECT 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 SUBJECT 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 SUBJECT MATERIALS without further

order of the Court. Examination of the SUBJECT MATERIALS shall be done in a secure environment

which will not expose the materials to other individuals not authorized to access the SUBJECT

MATERIALS.

10. The SUBJECT 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, SUBJECT 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 SUBJECT 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 SUBJECT 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 SUBJECT

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 SUBJECT MATERIALS, which shall be

kept in a secure location. Defense counsel need not disclose to the government any work product that

incorporates any SUBJECT 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



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government will maintain a copy of the SUBJECT MATERIALS. The government will maintain the

SUBJECT 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 SUBJECT 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

SUBJECT 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 SUBJECT

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 SUBJECT 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

United States Attorney

By: ____________________ WILLIAM FRENTZEN SUSAN BADGER S. WAQAR HASIB Assistant United States Attorneys

Dated: ______________

J. TONY SERRACounsel for defendant Kwok Cheung CHOW

Dated: ______________

JAMES LASSARTCounsel for defendant Leland Yin YEE



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Dated:_______

GILBERT EISENBERG Counsel for defendant George NIEH

Dated: ______________

JAMES BROSNAHAN Counsel for defendant Keith JACKSON

Dated: ______________

ROBERT WAGGENER Counsel for defendant Kevin SIU

Dated: ______________

SARA ELLEN RIEFCounsel for defendant Alan CHIU

Dated: ______________

CLAIRE LEARYCounsel for defendant Kongphet CHANTHAVONG

Dated: ______________

DORON WEINBERG Counsel for defendant Xiao Cheng MEI

Dated: ______________

TONY TAMBURELLO Counsel for defendant Brandon Jamelle JACKSON

Dated: ______________

KURT KEVIN ROBINSON Counsel for defendant Marlon Darrell SULLIVAN

Dated: ______________

GARRICK LEWCounsel for defendant Rinn ROEUN

Dated: ______________

WINSTON CHANCounsel for defendant Andy LI

Dated: ______________

DENNIS RIORDANCounsel for defendant Leslie YUN



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Dated: ______________

TERESA CAFFESECounsel for defendant Yat Wa PAU

Dated: ______________

JAI GOHELCounsel for defendant Jane Miao Xhen LIANG

Dated: ______________

MICHAEL STEPANIAN Counsel for defendant Tina Yao Gui LIANG

Dated: ______________

HARRIS TABACKCounsel for defendant Bryant TILTON

Dated: ______________

ROGER PATTONCounsel for defendant Huan Ming MA

Dated: ______________

EDWIN PRATHERCounsel for defendant Hon Keung SO

Dated: ______________

JULIA JAYNECounsel for defendant Norge MASTRANGELO

Dated: ______________

RANDY KNOXCounsel for defendant Albert NHINGSAVATH

Dated: ______________

[NAME]Counsel for defendant Serge GEE

Dated: ______________

NICOLE GIACINTICounsel for defendant Xiu Ying Ling LIANG

Dated: ______________

JONATHAN PIPERCounsel for defendant Gary Kwong Yiu CHEN



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Dated: ______________

CHRISTOPHER CANNON Counsel for defendant Anthony John LAI

Dated: ______________

[NAME]Counsel for defendant Tong Zao ZHANG

Dated: ______________

[NAME]Counsel for defendant Zhanghao WU

Dated: ______________

ELIZABETH FALKCounsel for defendant Barry Blackwell HOUSE

Dated: ______________

JONATHAN MCDOUGALL Counsel for defendant Wilson Sy LIM

IT IS SO ORDERED. Dated: ____________

HON. CHARLES R. BREYER United States District Judge


Documents

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