USA v. Tolentino et al

1	S TIPULATION AND [P ROPOSED ] P ROTECTIVE O RDER
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ERIC GRANT
United States Attorney
ROBERT ABENDROTH
NICOLE M. VANEK
Assistant United States Attorneys
501 I Street, Suite 10-100
Sacramento, CA 95814
Telephone: (916) 554-2700
Facsimile: 	(916) 554-2900
Attorneys for Plaintiff
United States of America
IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
v.
JUAN MUNOZ-GUZMAN,
Defendant.
CASE NO. 2:25-CR-00247-DJC
STIPULATION AND JOINT REQUEST FOR
PROTECTIVE ORDER; [PROPOSED]
PROTECTIVE ORDER
I. 	STIPULATION
1. 	Plaintiff United States of America, by and through its counsel of record, and Defendant
Juan Munoz-Guzman), by and through their respective counsel of record (“Defendant” and “Defense
Counsel”), for the reasons set forth below, hereby stipulate, agree, and request that the Court enter a
Protective Order in this case restricting the use and dissemination of certain materials that could identify
undercover agents and/or confidential sources, and/or that contain personal identifying information
(“PII”) and other confidential information of real persons.
2. 	This Court may enter protective orders pursuant to Rule 16(d) of the Federal Rules of
Criminal Procedure, Local Rule 141.1, and its general supervisory authority.
3. 	On October 30, 2025, a grand jury returned an indictment in this case.
4. 	As part of its investigation in the above-captioned case, the government is in the
possession of documents and other materials relating to the charges against the Defendant and seeks to

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provide those materials to counsel for the Defendant. The government seeks to do so pursuant to its
discovery obligations, although some of the materials may exceed the scope of the government’s
discovery obligations and will be produced to promote a prompt and just resolution of the case.
5. 	The government intends to produce to Defense Counsel: (1) audio recordings, video
recordings, photographs, investigative reports and/or other documents that could identify law
enforcement undercover agents and/or confidential sources; and/or (2) materials containing PII and other
confidential information of real persons. These real persons are third parties, co-conspirators, and/or
witnesses to this case. This discovery will be considered “Protected Material” as described in this
stipulation and order, as will any other discovery marked as Protected Material.
6. 	The purpose of this stipulation and order is to establish the procedures that must be
followed by Defense Counsel, any designated employees, and any other individual who receives access
to any Protected Material in this case and the information therein.
7. 	The Government shall produce the aforementioned Protected Material to Defense
Counsel, designating the discovery with the bates prefix, “TOLENTINO_ETAL_PM_.” This discovery,
and any subsequent material discovered by the Government to Defense Counsel using the bates-prefix,
shall be considered Protected Material.
a) 	For purposes of this Order, the term “Defense Team” refers to (1) the defendant’s
counsel of record, (2) other attorneys at defense counsel’s law firm or defense organization who may be
consulted regarding case strategy in the above-captioned matter, (3) defense investigators who are
assisting defense counsel with this case, (4) retained experts or potential experts (including, but not
limited to, mitigation specialists and their staff), and (5) paralegals, legal assistants, and other support
staff to defendant’s counsel of record providing assistance on this case. The term “Defense Team” does
not include defendant, the defendant’s family, or other associates of the defendant.
b) 	The United States intends to produce to the Defense Team, as defined below,
materials containing personal identifying information (“PII”) and other confidential information of real
persons, including, among other things, personal names, addresses, Social Security numbers, employers,
and bank account numbers.

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8. 	All Protected Material in this case is now and will forever remain the property of the
Government. It is entrusted to Defense Counsel only for purposes of representing their respective
Defendant, and Defense Counsel may retain all Protected Material for a length of time consistent with
their ethical obligations. While the Protected Material is in the possession of Defense Counsel, Defense
Counsel agrees to maintain the Protected Material in accordance with the terms of this Protective Order.
9. 	Defense Counsel shall not give any Protected Material to any person other than Defense
Counsel’s staff assisting in preparation of the present case. The term “staff” shall explicitly include only
attorneys, paralegals, legal assistants, retained experts, and investigators assisting Defense Counsel in
the present matter. The term excludes any person involved in any case in which discovery concerning
the Defendant is produced and any other person other than those specifically authorized to see Protected
Material under this paragraph.
10. 	Any person receiving access to the Protected Material from Defense Counsel shall be
bound by the same obligations as Defense Counsel and, further, may not give any Protected Material to
anyone.
11. 	No members of any Defendant’s family, any friends of the Defendant, personal or
professional associates of the Defendant, or any other person affiliated with the Defendant shall be given
access to any Protected Material or its contents in any manner, unless that individual is a potential
witness and access to Protected Material is necessary for a Defendant’s defense. Some of the Defendants
in this case are family members, and the government will disclose discovery individual to each
Defendant. If a Defense Counsel provides determines that they must provide access to the Protected
Material to a potential witness for a Defendant’s defense, Defense Counsel must ensure that the
Protected Material remains secure by taking the following measures: 1.) access to a potential witness
must be overseen by a member of the Defense Team, 2.) Defense Counsel may not leave copies of the
Protected Materials with the potential witness and ensure that the potential witness does not make copies
of the Protected Materials, and 3.) Defense Counsel must take steps, such as redacting PII, to ensure that
a potential witness does not see PII found in the Protected Material.
12. 	Defense Counsel may make copies of Protected Material and may take written or typed
notes summarizing it in connection with preparation of the case. If necessary to the litigation of the

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instant matter, Defense Counsel may also have audio or video forms of Protected Material transcribed.
Except for items constituting attorney work product, all notes, copies, duplicates, summaries, transcripts,
or other representations of or concerning the information in the Protected Material comprises “Protected
Material” itself, must be affixed with the corresponding bates numbers and the “Protected Material”
ledger, and is subject to all terms of this stipulation and order.
13. 	Defense Counsel shall maintain a list of persons to whom any Protected Material is being
or has been given. Such persons shall be provided with a copy of the executed version of this stipulation
and order, shall sign their full names to a copy, and shall in writing acknowledge that they understand its
terms and are bound by it. If Defense Counsel is replaced for any reason, or if new counsel is appointed
in any phase of the matter, the new counsel shall not have access to any Protected Material until and
unless they sign a copy of this stipulation and order, under the terms described in this paragraph. This
paragraph does not prohibit defense counsel or a member of the Defense Team from reviewing the
contents of Protected Material with potential witnesses as necessary to defend their client provided that
the Defense Team oversees the review of the Protected Material, does not allow the potential witness to
copy the Protected Material, and redacts or otherwise protects from access PII within the Protected
Material during witness review.
14. 	Defense Counsel may use the Protected Material in the defense of the instant case in any
manner deemed essential to adequately represent their respective clients (i.e., in motions that are filed
under seal, if necessary; in ex-parte applications as may be needed; and in reproducing and summarizing
Protected Material for use in trial preparation summaries, exhibits and as evidence, as may be needed),
consistent with this stipulation and order as it shall be originally prepared and signed.
15. 	In the event Defense Counsel needs to use any Protected Material in a manner not
authorized under this stipulation and order, Defense Counsel is entitled to seek to have this stipulation
and order amended by the District Court, after having given notice to counsel for the Government, in a
hearing before the District Court, in order to meet the obligations under the Sixth Amendment to the
United States Constitution.
16. 	Defense Counsel and any authorized members of Defense Counsel’s staff are authorized
to review with their respective Defendant the contents of the Protected Material. Defense Counsel and

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authorized members of their staff, however, are prohibited from in any way giving the Defendant any
Protected Material or any memorialization of the content of any of it, such as: any of the Protected
Material itself; copies of any of the Protected Material; copies of excerpts of any of the Protected
Material; or summaries of any of the Protected Material. This prohibition will not extend to the
Defendant viewing the Protected Material in open court should any of these materials or summaries
thereof be used in the litigation of this case. If, during the pendency of the case, the Defendant requests
a copy of the Protected Materials from Defense Counsel, Defense Counsel may provide a copy of the
Protected Materials to the defendant provided that Defense Counsel ensures that all PII contained in the
Protected Materials is fully redacted and the copy bears an inscription “PROTECTED MATERIALS
SUBJECT TO PROTECTIVE ORDER.” If Defense Counsel provides a redacted copy to the Defendant
subject to these conditions, Defense Counsel or a member of the Defense Team must
contemporaneously memorialize in writing that it has fully redacted PII from the Protected Materials
and complied with this Order. This written certification need not be disclosed or produced to the United
States unless ordered by the Court.
IT IS SO STIPULATED.
[CONTINUED ON NEXT PAGE]

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Respectfully Submitted,
Dated: January 7, 2026
By:
ERIC GRANT
United States Attorney
/s/ ROBERT ABENDROTH
ROBERT ABENDROTH
Assistant United States Attorney
Dated: January 7, 2026 	/s/ CLEMENTE JIMENEZ
CLEMENTE JIMENEZ
Counsel for Defendant
JUAN MUNOZ-GUZMAN
[PROPOSED] FINDINGS AND ORDER
The Court having read and considered the Stipulation and Joint Request for a Protective Order,
which this Court incorporates by reference into this Order in full, hereby finds that GOOD CAUSE
exists to enter the above Order.
IT IS SO FOUND AND ORDERED this 7th day of January, 2026.