9. The restrictions set forth in this Order do not apply to the United States, and

nothing in this Order limits the government’s use and/or dissemination of these materials.

10. The restrictions set forth in this Order do not apply to documents that are in the
public record or public domain. In addition, this Order does not apply to any materials that
defendant obtains from any sources other than the government.

ll. | The Order may be modified by the agreement of the parties with permission
of the Court or by further Order of the Court.

12. Any violation of this Order may result in imposition of civil and criminal
sanctions.

ENTER:

"SAMUEL DER-YEGHIA YAN
United States District Judge

Dated: December /Y, 2011


provided by the United States shall not be disclosed to anyone other than defendant,

defendant’s counsel, persons employed to assist the defense, agents working on behalf of
defendant’s counsel, or such other person as to whom the Court may explicitly order
disclosure.

6. Defendant’s counsel shall inform all employees or agents working on behalf
of defendant’s counsel to whom any of these materials are disclosed that the disclosure is
made pursuant to the terms of this Order; shall provide each of these individuals with a copy
of this Order; and shall direct each of these individuals to comply with the terms of this
Order.

7. Defendant’s counsel shall inform a potential witness, counsel for a potential
witness, a person with relevant knowledge, and counsel for a person with relevant knowledge
to whom any of these materials are disclosed that the disclosure is made pursuant to the terms
of this Order; shall provide each of these individuals with a copy of this Order; and shall
advise each of these individuals that they are obligated to comply with the terms of this
Order.

8. The materials produced by the United States shall not be copied or reproduced
by defendant’s counsel or defendant except so as to provide copies of these materials for the
use by defendant’s counsel and defendant and such persons as are employed by them to assist
in the defense, or agents working on behalf of defendant’s counsel, and such copies and

reproductions shall be treated in the same manner as the original matter.


UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION
UNITED STATES OF AMERICA )
) No. 11 CR 792
v. ) Judge Samuel Der-Yeghiayan
)
ROBERT G. NELSON )

AGREED PROTECTIVE ORDER

Upon the agreement of counsel for the government and counsel of record for
defendant (hereafter “defendant’s counsel”), it is hereby ORDERED as follows:

1. All material produced by the government in preparation for, or in connection
with, any stage of the proceedings in this case, including, but not limited to, grand jury
transcripts, agency reports, recorded conversations, witness statements, memoranda of
interview, and any document or tangible object, is subject to this protective order and the
material shall be divided into two categories: “Regular Discovery” and “Confidential”
materials.

2. The parties contemplate that the government may designate as Confidential any
item that it believes requires special protection. Defendant shall not file any Confidential
materials publicly with the Clerk of Court or with the Court without first attempting to obtain
the permission of the Court to file the Confidential materials under seal. After the case is
closed in the District Court, the parties may obtain the return of any previously-sealed or

previously-restricted documents by a motion filed within 60 days of the close of the case.


Any documents that are not withdrawn during that time period will become part of the public

case file.

3. All materials produced by the United States, including both Regular Discovery
and Confidential materials, remain the property of the United States. Upon conclusion of the
trial of this case and any direct appeals of this case, or upon the earlier resolution of the
charges against defendant, all of these materials and all copies made thereof shall be
destroyed, unless otherwise explicitly ordered by the Court. All materials or copies withheld
by defendant’s counsel by express order of Court shall be preserved only so long as is
necessary for further proceedings related to this cause, after which such materials or copies
shall be returned to the United States or destroyed. The Court may require a certification as
to the disposition of any such materials retained.

4. All materials produced by the United States may be utilized by defendant,
defendant’s counsel, and agents or employees working on behalf of defendant’s counsel
solely in connection with the defense of this case and for no other purpose and in connection
with no other proceeding. Defendant’s counsel and defendant shall not disclose these
materials either directly or indirectly to any person other than defendant, defendant’s counsel,
persons employed to assist in the defense, agents working on behalf of defendant’s counsel,
a potential witness to whom documents relevant to his/her testimony may be shown in
connection with the defense of this case (a “potential witness”), counsel for a potential

witness, a person believed to have knowledge relevant to the prosecution or defense where


it is believed that the person’s relevant knowledge may be enhanced by the opportunity to

examine the material (a “person with relevant knowledge”), counsel for person with relevant
knowledge, or such other persons as to whom the Court may explicitly order disclosure. Any
notes or records of any kind that defendant’s counsel or defendant may make relating to the
contents of materials provided by the United States shall not be disclosed to anyone other
than the defendant, defendant’s counsel, persons employed to assist the defense, agents
working on behalf of defendant’s counsel, a potential witness, counsel for a potential
witness, a person with relevant knowledge, counsel for a person with relevant knowledge,
or such other person as to whom the Court may explicitly order disclosure, and all such notes
and records shall not be disclosed except as provided by this Order.

5. When materials produced by the United States are disclosed to a potential
witness, counsel for a potential witness, a person with relevant knowledge, or counsel for a
person with relevant knowledge pursuant to the terms of this Order, neither the potential
witness, counsel for the potential witness, the person with relevant knowledge, nor counsel
for the person with relevant knowledge shall disclose these materials either directly or
indirectly to any person other than defendant, defendant’s counsel, persons employed to
assist in the defense, agents working on behalf of defendant’s counsel, or such other persons
as to whom the Court may explicitly order disclosure. Any notes or records of any kind that
a potential witness, counsel for a potential witness, a person with relevant knowledge, or

counsel for a person with relevant knowledge may make relating to the contents of materials