Case: 1:12-cr-00456 Document #: 45-1 Filed: 11/20/13 Page 4 of 4 PagelD #:211

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.

7 Demae

JOHN W. DARRAH
District Judge

United States District Court
Northern District of Illinois



Ce 1:12-cr-00456 Document #: 45-1 Filed: 11/20/13 Page 1 of 4 PagelD #208

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION
UNITED STATES OF AMERICA )
) No. 12 CR 456-1
v. ) Judge John W. Darrah
)
KRASSIMIRE ANGEEOV )
PROTECTIVE ORDER

In response to the government’s motion for a protective order, which is agreed to
by defendant Krassimire Angeeov and his counsel, pursuant to Fed. R. Crim. P. 16(d)(1)
and 18 U.S.C. § 3771(a)(1) and (a)(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 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 these 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. The materials and their contents shall not be disclosed either

ne



Case: 1:12-cr-00456 Document #: 45-1 Filed: 11/20/13 Page 2 of 4 PagelD #:209

directly or indirectly to any person or entity outside of the United States without prior
authorization from the Court.

3. Certain materials disclosed or to be disclosed by the government contain
particularly sensitive information, including financial information 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 defendant,
counsel for defendant, 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.

4. 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.

5. 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.



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

7. 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 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.

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 in the use

of discovery materials in judicial proceedings in this case, except that any document filed
3