UNITED STATES DISTRICT COURT <
NORTHERN DISTRICT OF ILLINOIS *, ty
WESTERNDIVISION een
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UNITED STATES OF AMERICA Whee °
No. 12 CR 50027 ag

v.
Magistrate Judge P. Michael Mahoney
RITA A. CRUNDWELL

PROTECTIVE ORDER GOVERNING DISCOVERY

Upon the agreed motion of the government, pursuant to Fed. R. Crim. P. 16(d), 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 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 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.

8



3. Defendant, defendant’s 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 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, absent prior permission from this
Court.

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.

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MICHAEL‘MAHONEY /
Magistrate Judge

United States District Court
Northern District of Illinois

Date:
and Jointly submitted bys
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PAULE. RUZ, Aten 4 for a DATE
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PH C. PEDERSEN, Assistant U.S. Attorney DATE