UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

UNITED STATES OF AMERICA
No. 12 CR 409
* Judge Ronald A. Guzman
ERIC A. BLOOM and
CHARLES K. MOSLEY
PROTECTIVE ORDER GOVERNING DISCOVERY

Upon the motion of the government, pursuant to Federal Rule of Criminal
Procedure 16(d) and 18 U.S.C. § 3771(a)(1) and (8), it is hereby ORDERED:

1. 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, without further order of this Court, may not
be used by defendants and defendants’ counsel (defined as counsel of record in this
case) in connection with any other proceeding, including U.S. Securities and Exchange
Commission v. Sentinel Management Group, Inc. et al., 07 C 4684, a matter pending
in the U.S. District Court for the Northern District of Illinois, U.S. Commodity Futures
Trading Commission v. Sentinel Management Group, Inc. et al., 08 C 2410, a matter
pending in the U.S. District Court for the Northern District of Illinois, and Frederick
J. Grede, as Bankruptcy Trustee for Sentinel Management Group, Inc. v. Eric A. Bloom
et al., 07 B 14987, a matter pending in the bankruptcy court for the Northern District

of Illinois, or any other lawsuit filed as a result of the failure or bankruptcy of Sentinel

Management Group, Inc.


2. Defendants and defendants’ counsel shall not disclose the materials or
their contents directly or indirectly to any person 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. In no event shall defendants, defendants’
counsel, and authorized persons publish or make available to any news media any of
the materials without having received prior permission from 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

2


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 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 materials that are
or become part of the public court record, nor do the restrictions set forth in this Order
apply to materials that been obtained by the defendants in other legal proceedings.

9. Nothing in this Order shall preclude any party from applying to this

Court for further relief or for modification of any provision hereof.

RONALD A. GU N
District Judge

United States District Court
Date: & 22/ 20/2 Northern District of Illinois

3