USA v. Done Global, Inc et al

STIPULATION AND PROTECTIVE ORDER [PROPOSED]
25-CR-00432 CRB 	1
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CRAIG H. MISSAKIAN (CABN 125202)
United States Attorney
RAVI T. NARAYAN (CABN 331858)
Deputy Chief, Criminal Division
LORINDA LARYEA (DCBN 99769)
Chief, Fraud Section
JIL SIMON (DCBN 1030206)
Trial Attorney, Fraud Section
SANDOR A. CALLAHAN (CABN 318200)
Trial Attorney, Fraud Section
U.S. Department of Justice, Fraud Section
1400 New York Avenue NW
Washington, DC 20005
Telephone: 202-514-2000
Jil.Simon@usdoj.gov
Sandor.Callahan2@usdoj.gov
KRISTINA GREEN (NYBN 5226204)
Assistant United States Attorney
450 Golden Gate Avenue, P.O. Box 36055
San Francisco, CA 94102-3495
Telephone: (415) 436-7200
Kristina.Green@usdoj.gov
Attorneys for United States of America
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
DONE GLOBAL, INC. and
MINDFUL MENTAL WELLNESS P.A.,
Defendants.
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No. 25-CR-00432 CRB
STIPULATION AND PROTECTIVE ORDER
Judge: Hon. Charles R. Breyer
Case 3:25-cr-00432-CRB Document 28 Filed 03/13/26 Page 1 of 6

STIPULATION AND PROTECTIVE ORDER [PROPOSED]
25-CR-00432 CRB 	2
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With the agreement of the parties, the Court enters the following Protective Order:
Defendant Done Global, Inc. (“Done Global”) is charged with violations of 21 U.S.C. §§ 846,
841, 18 U.S.C. § 1349, and 18 U.S.C. § 1512(k), and defendant Mindful Mental Wellness P.A.
(“MMW”) is charged with a violation of 21 U.S.C. § 846 (collectively, the “defendants”). The Court
has ordered that this case is related to United States v. He and Brody, CR 24-00329 CRB (the “related
case”).
The United States previously produced documents and other materials in the related case that
pertains to the defendants in this case (“Related Case Discovery”). The United States represents that it
will produce the same discovery with the same Bates numbers to the defendants in this case, along with
other discovery (“Discovery”). Defense counsel represents that the Related Case Discovery is hosted in
part in an e-discovery platform where access is limited by the protective order entered in the related
case. The terms of this protective order apply both to Discovery and Related Case Discovery, whether
reviewed by the Defendants through that e-discovery platform or otherwise.
Upon receipt of a discovery request, the United States will produce Discovery to defense counsel
in this case, including documents and other materials pertaining to the defendants and the charged
offenses. The Discovery to be provided includes sensitive information, including but not limited to:
1. 	Personal identifying information of any individual (other than his or her name), including any
person’s date of birth, social security number, residence address, telephone numbers, email
addresses, driver’s license number, names of persons who are minors, or criminal histories
(“Personal Identifying Information”);
2. 	Financial identifying information of any individual or business, including bank account
numbers, credit or debit card numbers, account passwords, and taxpayer identification
numbers (“Financial Identifying Information”); and
3. 	Medical records or other patient information of any individual covered by the Health
Insurance Portability and Accountability Act of 1996 (HIPAA) (“Medical Information”).
The information described above is found throughout the Discovery in this case, and it would be
unduly burdensome for the government to attempt to segregate this information from the remaining
portions of the Discovery that do not contain such information. It is anticipated that this Discovery will
Case 3:25-cr-00432-CRB Document 28 Filed 03/13/26 Page 2 of 6

STIPULATION AND PROTECTIVE ORDER [PROPOSED]
25-CR-00432 CRB 	3
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include, among other records, thousands of pages of records from a variety of sources, which will
contain the types of information described above. It would be contrary to the interests of justice to
indiscriminately disclose such information to the general public. Moreover, it would be unduly
burdensome for the government to attempt to redact as necessary the sensitive information found
throughout the Discovery.
Accordingly, IT IS HEREBY ORDERED that, in order to protect the confidentiality of any
sensitive information that is contained in the Discovery, only defense counsel, defense counsel’s
employees, agents, assistants, independent contractors, investigators, consultants, and experts,
(collectively, “the Defense Team”) and the defendants may review the Discovery provided by the
government in preparation for trial, and the Defense Team and the defendants may only use the
Discovery and the information provided therein for the specific purpose of preparing or presenting a
defense in this matter, and for no other purpose. For purposes of this Order, the term “defendants”
includes any current employees, officers, or agents of any corporate defendant who are assisting in the
preparation of the defense of this matter.
The government may designate certain Discovery as “U.S. Personnel Only” if the Discovery
contains sensitive personal health information and financial data of U.S. persons.1 Discovery produced
by the government and designated as “U.S. Personnel Only” shall not be transferred outside of the
United States or Canada by or to people who are not members of the Defense Team, but the Defense
Team may display Discovery designated as “U.S. Personnel Only” and provide read-only access to such
persons located outside of the United States or Canada for the purpose of preparing a defense. Such
read-only access will not permit Discovery designated as “U.S. Personnel Only” to be exported or
downloaded by people located outside of the United States or Canada. The government shall provide a
list of Bates numbers for all Discovery designated by the government as “U.S. Personnel Only”.
Any defendant may challenge a designation of “U.S. Personnel Only” at any time. The
1 The government has endeavored to identify every copy of such documents that contain the
personal health information and financial data of U.S. persons, however, there may be copies within the
production including, for example, attachments to interview reports that were not explicitly
designated. The government reserves the right to designate a document as “U.S. Personnel Only”
following any production.
Case 3:25-cr-00432-CRB Document 28 Filed 03/13/26 Page 3 of 6

STIPULATION AND PROTECTIVE ORDER [PROPOSED]
25-CR-00432 CRB 	4
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challenge shall be initiated by providing written notice of each designation at issue and describing the
basis for each challenge. The parties shall attempt to resolve each challenge in good faith and must
begin the process by conferring directly in person or by videoconference within 14 days of the date of
service of notice. If the parties cannot resolve a challenge without court intervention, the defendant may
seek relief from the Court through a motion. The defendants shall continue to treat such information as
“U.S. Personnel Only” pending resolution of the objection. The burden of persuasion in any such
challenge proceeding shall be on the government as the designating party to demonstrate why the
designated item at issue should be restricted to “U.S. Personnel Only” as described above.
All “U.S. Personnel Only” markings are for pre-trial use only and all such markings will be
removed from any documents used in trial or shown to jurors in this matter.
The Defense Team may show witnesses and any counsel for witnesses Discovery in the course
of preparing a defense for trial or any related proceedings in this case, but only if (i) the witness, by
reason of their participation in the underlying events or conduct, would have seen or had reason to know
such information, or (ii) it is otherwise relevant to the defense of the case that the Defense Team discuss
with or show the witness the Discovery. Witnesses may only view the Discovery in the presence of the
Defense Team.2 No witness or potential witness may retain copies of Discovery material after his or her
review of those materials with the Defense Team is complete. This paragraph’s limitations on witnesses
shall not apply to any individual qualifying as a defendant under the definition above.
Notwithstanding any other provision of this Stipulation, if defense counsel redacts all Personal
Identifying Information, Financial Identifying Information, and Medical Information from Discovery,
presents such material to the government for their confirmation and approval that all confidential
information has been redacted, or confirms that there is no information that needs to be redacted, and
receives confirmation of the same, such material will no longer be considered confidential subject to this
Order. The government will work promptly to review the redacted material and provide confirmation
and approval.
IT IS FURTHER ORDERED that after any judgment or disposition has become final and there
2 “In the presence of the Defense Team” includes both in-person meetings and screen sharing
during videoconference meetings.
Case 3:25-cr-00432-CRB Document 28 Filed 03/13/26 Page 4 of 6

STIPULATION AND PROTECTIVE ORDER [PROPOSED]
25-CR-00432 CRB 	5
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are no pending proceedings, challenges, appeals, or habeas motions in the case, counsel for defendants
shall either destroy Discovery materials within 30 days if the defendants consent to such destruction, or
retain the Discovery materials and ensure that the Discovery materials will continue being kept under
the conditions specified in this Order. After the statutory period for filing a motion under 28 U.S.C. §
2255 has expired, the United States is free to destroy documents and materials subject to this Order. If a
defendant is represented by counsel and files a motion pursuant to 28 U.S.C. § 2255, the United States
will provide counsel with the documents and materials subject to this Protective Order under the terms
of this Order.
This stipulation is without prejudice to either party applying to the Court to modify the terms of
any protective order. This Court shall retain jurisdiction to modify this Order upon motion of either
party even after the conclusion of district court proceedings in this case.
IT IS SO STIPULATED
CRAIG H. MISSAKIAN
United States Attorney
_/s/_______________________
JIL SIMON
SANDOR A. CALLAHAN
Trial Attorneys
Fraud Section, U.S. Department of Justice
_/s/_______________________
KRISTINA GREEN
Assistant United States Attorney
_/s/_______________________
CHRISTOPHER J. STESKAL
Counsel for Defendant Done Global
_/s/_______________________
TED W. CASSMAN
RAPHAEL M. GOLDMAN
Counsel for Defendant MMW
Case 3:25-cr-00432-CRB Document 28 Filed 03/13/26 Page 5 of 6

STIPULATION AND PROTECTIVE ORDER [PROPOSED]
25-CR-00432 CRB 	6
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IT IS SO ORDERED
________________________
HON. CHARLES R. BREYER
United States District Judge
Date: March 13, 2026
Case 3:25-cr-00432-CRB Document 28 Filed 03/13/26 Page 6 of 6