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:

rung, PI
YOUNG R/ KIM
‘agistrate Judge
United States District Court
Northern District of Illinois

Date: 06-76-IL



UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

UNITED STATES OF AMERICA

No. 12 CR 459

v.

Magistrate Judge

JOSEPH MARIO MORENO, YOUNG B. KIM
also known as “Mario Moreno’;

AMBROSIO MEDRANO;
STANLEY WOZNIAK;

GERALD W. LOMBARDI,

also known as “Jerry Lombardi, Sr.”; and
JERRY A. LOMBARDI, JR.,

also known as “Jerry Lombardi, Jr.”

PROTECTIVE ORDER GOVERNING DISCOVERY OF WIRETAP MATERIALS

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

1. The applications, affidavits, and court orders authorizing the
interception of wire communications in this case, which were provided to
defendants’ counsel by the United States on June 28, 2012, (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 destroyed or returned to the United States, unless

otherwise ordered by the Court. The Court may require a certification as to the



disposition of any such materials.

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 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.