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 3, above, shall be filed under seal to
the extent necessary to protect such information, absent prior permission from this
Court.

10. 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:
NAN R. NOLAN

Magistrate Judge
United States District Court
Northern District of Illinois



UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERNDIVISION

UNITED STATES OF AMERICA
No. 12 CR
v.
Magistrate Judge NAN R. NOLAN
YASEEN AHMED,

ELIOT HIGUEROS,
RAZZAK KHADER,
THEODORE CARDENAS,
JOHN WELCH,
AMANDA FANARO, and
KRISTIN DAUGHERTY

PROTECTIVE ORDER GOVERNING DISCOVERY

Upon the motion of the government, pursuant to Fed. R. Crim. P. 16(d) and 18
U.S.C. § 3771(a)(1) and (8), 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. Certain materials disclosed or to be disclosed by the government contain
particularly sensitive information, including financial information and dates of birth,
home addresses, and social security numbers of one or more persons other than the
defendant to whom the information is disclosed. These materials shall be plainly
marked as sensitive by the government prior to disclosure. No such materials, or the
information contained therein, may be disclosed to any persons other than defendants,
counsel for defendants, persons employed to assist the defense, 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 (except in the case of a defendant
who chooses to include in a public document sensitive information relating solely and
directly to the defendant making the filing).

4, 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.

5. 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

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materials, other than to authorized persons, and all such notes or records are to be
treated in the same manner as the original materials.

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

Ts 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.

8. To the extent any material is produced by the United States to defendants
or defendants’ 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, 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.

9. 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

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