UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS

EASTERNDIVISION
UNITED STATES OF AMERICA
No. 12 CR 168
v.
Judge JOHN W. DARRAHL
AIMAN OTHMAN

PROTECTIVE ORDER GOVERNING DISCOVERY

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

1. All of the sensitive materials provided by the United States in preparation for,
or in connection with, any stage of the proceedings in this case (collectively, "the sensitive
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.

2. Defendant and defendant’s counsel shall not disclose the sensitive materials
contained in the discovery materials 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”). As used in this order, sensitive
materials include, but is not limited to, names, addresses, dates of birth, social security

numbers, tax identification numbers, license plate numbers, or any other identifying



information of a personal nature. Potential witnesses and their counsel may be shown copies
of the sensitive materials as necessary to prepare the defense, but may not retain copies
without prior permission of the Court.

3. Defendant, defendant’s counsel, and authorized persons shall not copy or
reproduce the sensitive materials except in order to provide copies of the sensitive 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
sensitive materials.

4. Defendant, defendant’s counsel, and authorized persons shall not disclose any
sensitive materials of the kind described above and found in the contents of the materials,
other than to authorized persons, and all such information are to be treated in the same
manner as the original sensitive materials.

5. Before providing sensitive 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 sensitive materials and all
copies made thereof shall be disposed of in one of three ways, unless otherwise ordered by
the Court. The sensitive 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 sensitive materials. In the event that the sensitive materials are
retained by defense counsel, the restrictions of this Order continue in effect for as long as the

sensitive materials are so maintained, and the sensitive materials may not be disseminated



or used in connection with any other matter without further order of the Court.

7. To the extent any sensitive 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 sensitive 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 sensitive
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 sensitive
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.

SLodnwe

JOHN W. DARRAH

Judge

United States District Court
Northern District of Illinois

Date: i) ° 25-12