UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

UNITED STATES OF AMERICA
No. 12 CR 170
Vv.
Judge RONALD A. GUZMAN
MOHAMMAD AL SAKHLEH, et al.
PROTECTIVE ORDER GOVERNING DISCOVERY

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

1. All of the 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 defendants and
defendants’ 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.

2. Defendants and defendants’ counsel shall not disclose the materials or
their contents directly or indirectly to any person or entity other than persons
employed to assist in the defense, persons who are interviewed as potential
witnesses, counsel for potential witnesses, and other persons to whom the Court
may authorize disclosure (collectively, “authorized persons”). Potential witnesses

and their counsel may be shown copies of the materials as necessary to prepare the

defense, but may not retain copies without prior permission of the Court.



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

4, Defendants, defendants’ 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
defendants or defendants’ counsel by mistake, the United States shall have the

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right to request the return of the material and shall do so in writing. Within five
days of the receipt of such a request, defendants and/or defendants’ 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.

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:

Colds

RONALD A. GUZMAN
Judge

United States District Court
Northern District of Illinois

Date: IE 7/ >