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.

EN] tim
2

GARY FEINERMAN
District Judge

United States District Court
Northern District of Illinois

Date: Al 6 | 252



UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION
UNITED STATES OF AMERICA
No. 12 CR 459
Vv.
Judge Gary Feinerman
JOSEPH MARIO MORENO, et al.

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 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. Any materials containing taxpayer information obtained from the Internal
Revenue Service shall be plainly marked as such by the government prior to disclosure. No
such materials, or the information contained therein, may be disclosed to any persons other
than defendants, defendants’ counsel, persons employed to assist the defense, or the taxpayer
on whose behalf such information was provided to the Internal Revenue Service, without
prior notice to the government and authorization from the Court. Absent prior permission
from the Court, taxpayer information obtained from the Internal Revenue Service shall not
be included in any public filing with the Court, and instead shall be submitted under seal (this
Order does not, however, prohibit a defendant from making a public filing containing the
defendant's own taxpayer information).

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 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.

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 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 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 the contents of taxpayer information obtained
from the Internal Revenue Service (other than taxpayer information relating solely to the
defendant filing the document in question), shall be filed under seal to the extent necessary

to protect such information, absent prior permission from this Court.