UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

UNITED STATES OF AMERICA

No. 12 CR 454
Vv.

Judge Robert W. Gettleman
AMBER LEARN, et al.

PROTECTIVE ORDER GOVERNING DISCOVERY

Upon the unopposed 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. 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 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 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.
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:

:
ROBERT W. GETTLEMAN
District Judge

United States District Court
Northern District of Illinois

10.

Date: Vyut 2 24\