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.

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:

bw .(golitia—

ROBERT W. GETTLEMAN
District Judge

United States District Court
Northern District of Illinois

Date: | 20 (>



UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

UNITED STATES OF AMERICA
No. 12 CR 411
v.
Judge Robert W. Gettleman
HAKEEM RASHID,
KAREEM BROUGHTON,
MARGUERITE ELISE DIXON-ROPER,
aka ELISE DIXON, and
JADA ELAINE LUCAS,
fka SOPHIA YOUSSEF

PROTECTIVE ORDER GOVERNING DISCOVERY

Upon the motion of the government, pursuant to Fed. R. Crim. P. 16(d) and 18
US.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

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