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1-10-cr-00576 345-1 Exhibit A

1-10-cr-00576 345-1 Exhibit A

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Published by scribd.hi.lgns8853
Exhibit A, part of an Order Granting Continuance in a case the US Department of Justice has described as the largest human trafficking case in US history. The document explains the complexity of this case.

The case was to go to trial on February, 2012, but the DOJ requested a continuance due to the complexity of segregating documents that are protected by attorney-client privilege. The court approved a six month delay, setting a new date of August 8, 2012.
Exhibit A, part of an Order Granting Continuance in a case the US Department of Justice has described as the largest human trafficking case in US history. The document explains the complexity of this case.

The case was to go to trial on February, 2012, but the DOJ requested a continuance due to the complexity of segregating documents that are protected by attorney-client privilege. The court approved a six month delay, setting a new date of August 8, 2012.

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Published by: scribd.hi.lgns8853 on Dec 21, 2011
Copyright:Public Domain

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12/21/2011

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FLORENCE T. NAKAKUNI #2286UNITED STATES ATTORNEYDistrict of HawaiiROBERT J. MOOSSY, JR.Principal Deputy ChiefDANIEL H. WEISSTrial AttorneyHuman Trafficking Prosecution UnitCriminal Section, Civil Rights DivisionWashington, D.C. 20530Telephone: (202) 616-6594Facsimile: (202) 616-0372Email: Daniel.Weiss@usdoj.govAttorneys for PlaintiffUNITED STATES OF AMERICAIN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF HAWAIIUNITED STATES OF AMERICA, )CR. NO. 10-00576-SOM)Plaintiff, )EXHIBIT A (RULE 502(d) PROTECTIVE)ORDER)V. ))MORDECHAI ORIAN, (01) )aka “Motty,” )PRANEE TUBCHUMPOL, (02) )aka “Som,” )RATAWAN CHUNHARATAI,(05) )PODJANEE SINCHAI, (06) )aka “Pojanee Loichurn,” )aka “Pojanne,” )aka Jeh Maew,)JOSEPH KNOLLER,(08) ))Defendants. ))EXHIBIT A (RULE 502(d) PROTECTIVE ORDER)IT IS ORDERED, upon the United States’ Renewed Motionfor Continuance and Motion for Order Regarding Protection ofDefendant Orian’s Asserted Attorney-Client Privilege, that:
Case 1:10-cr-00576-SOM Document 345-1 Filed 12/20/11 Page 1 of 5 PageID #: 3139
 
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1. The trial date in this matter is continued until August28, 2012 at 9:00 a.m., with a final pretrial conference set forJuly 30, 2012 at 1:30 p.m.;2. The United States shall provide electronic copies of thefiles seized from Defendant Orian’s 72 hard drives, without firstscreening out documents containing Defendant Orian’sattorney-client privileged communications, to DefendantsTubchumpol, Knoller, and Orian, on a rolling basis, beginningimmediately and completing all production by February 27, 2012;3. The United States shall identify to DefendantsTubchumpol, Knoller, and Orian which documents in the productionare potentially privileged based on “hits” for search termsprovided by Defendant Orian (“the potentially privileged files”);4. Pursuant to Rule 502(d) of the Federal Rules ofEvidence, the Court orders that the disclosure of the files fromDefendant Orian’s 72 hard drives is and shall be made withoutwaiver of any attorney-client privilege or work-productprotection (collectively referred to herein as “privilege”);5. The disclosure of any file from Defendant Orian’s 72hard drives that is or may be subject to an assertion ofprivilege shall be deemed to be without prejudice to anyassertion that such material is privileged, and such disclosureshall not, in and of itself, be deemed to waive Defendant Orian’sassertion of privilege, or estop Defendant Orian from designating
Case 1:10-cr-00576-SOM Document 345-1 Filed 12/20/11 Page 2 of 5 PageID #: 3140
 
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the file as privileged at a later date;6. The United States’ taint team will screen and conduct aprivilege review of a limited number of the potentiallyprivileged files from Defendant Orian’s 72 hard drives, ratherthan all of the potentially privileged files, and the UnitedStates shall set forth the number and procedure by which itselected the potentially privileged files that were reviewed inits document production to Defendants;7. Based on its review, the United States’ taint team willprovide a list of documents it is designating as privileged toDefendants Tubchumpol, Knoller, and Orian, by notifying them ofthe location in the production, but not the contents, of thefiles;8. The United States’ prosecution team will not review anyof the potentially privileged files, unless they have first beenscreened by the United States’ taint team;9. If, based on its review of files from the 72 hard drivesthat were not in the group of potentially privileged files, theUnited States’ prosecution team reviews any document thatreasonably appears to be privileged, the prosecution team shallstop reviewing the document and refer the document to the UnitedStates’ taint team;10. The United States’ taint team will make privilegedeterminations regarding any files referred to the taint team
Case 1:10-cr-00576-SOM Document 345-1 Filed 12/20/11 Page 3 of 5 PageID #: 3141

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