9. Nothing contained in this Order shall preclude any party from applying to
this Court for further relief or for modification of any provision hereof.

ENTER:

Vn. Vogl
Ar CAGES

United States District Court
Northern District of Illinois

Date: MAR 09 202



Wo

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION
UNITED STATES OF AMERICA
No. 12 CR 124
Vv.
Judge James B. Zagel
WILLIAM BEAVERS

PROTECTIVE ORDER GOVERNING DISCOVERY

Upon the motion of the government, pursuant to Fed. R. Crim. P. 16(d), it is
hereby ORDERED:

1. Certain materials provided by the United States in preparation for, or in
connection with, any stage of the proceedings in this case (collectively, "the materials")
are subject to this protective order and may be used by defendant and defendant’s counsel
(defined as counsel of record in this case) solely in connection with the defense of this
case, and for no other purpose, and in connection with no other proceeding, without
further order of this Court. Specifically, all documents containing financial information
of third party individuals, including their gambling records, are subject to this protective
order, These materials are marked with bates stamp numbers beginning with the
following prefixes:

a. CITIBK_PY
b. CITILHD_PY
c. CMIPY

d. -HHCAS 2



This protective order does not apply to defendant’s own records.

2. These materials contain particularly sensitive information, including
financial information of one or more persons other than the defendant. These materials
shall be plainly marked as sensitive by the government prior to disclosure. Defendant and
defendant’s counsel shall not disclose the materials or their contents directly or indirectly
to any person or entity other than persons employed to assist the defense (“authorized
persons”), or the person to whom the sensitive information solely and directly pertains,
without prior notice to the government and authorization from the Court. Absent prior
permission from the Court, information marked as sensitive shall not be included in any
public filing with the Court, and instead shall be submitted under seal.

3. Defendant and defendant’s counsel shall not copy or reproduce the
materials except in order to provide copies of the materials for use in connection with this
case by defendant, defendant’s counsel, and authorized persons. Such copies and
reproductions shall be treated in the same manner as the original materials.

4. Defendant, defendant’s counsel, and authorized persons shall not disclose
any notes or records of any kind that they make in relation to the contents of the
materials, other than to authorized persons, and all such notes or records are to be treated
in the same manner as the original materials.

5. Before providing materials to an authorized person, defense counsel must
provide the authorized person with a copy of this Order.

6. Upon conclusion of all stages of this case, all of the materials and all copies

made thereof shall be disposed of in one of three ways, unless otherwise ordered by the



Court. The materials may be (1) destroyed; (2) returned to the United States; or (3)
retained in defense counsel's case file. The Court may require a certification as to the
disposition of any such materials. In the event that the materials are retained by defense
counsel, the restrictions of this Order continue in effect for as long as the materials are so
maintained, and the materials may not be disseminated or used in connection with any
other matter without further order of the Court.

7. To the extent any material is produced by the United States to defendant or
defendant’s counsel by mistake, the United States shall have the right to request the return
of the material and shall do so in writing. Within five days of the receipt of such a
request, defendant and/or defendant’s counsel shall return all such material if in hard
copy, and in the case of electronic materials, shall certify in writing that all copies of the
specified material have been deleted from any location in which the material was stored.

8. The restrictions set forth in this Order do not apply to documents that are or
become part of the public court record, including documents that have been received in
evidence at other trials, nor do the restrictions in this Order limit defense counsel in the
use of discovery materials in judicial proceedings in this case, except that any document
filed by any party which attaches or otherwise discloses specially identified sensitive
information as described in Paragraph 2, above, shall be filed under seal to the extent

necessary to protect such information, absent prior permission from this Court.