UNITED STATES DISTRICT COURT 4
NORTHERN DISTRICT OF ILLINOIS 4
WESTERN DIVISION — Zi ©

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UNITED STATES OF AMERICA See, YN s

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vs. ) No. 12 CR 50023 Teri
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LATOYA SHAUNTA BURROWS ) Magistrate Judge Mahoney

PROTECTIVE ORDER

Upon the agreed motion of the parties for a protective order, it is hereby ordered as
follows:

1. All materials produced by the government in preparation for or in conjunction
with any stage of the proceedings in this case, including but not limited to grand jury
transcripts, agency reports, witness statements, memoranda of interview, and any documents
provided by the government, excluding trial exhibits, remain the property of the United
States. Within 30 days following the later of sentencing, conclusion of an appeal, or an
earlier resolution of charge(s) against the defendant, all such materials and all copies made
thereof shall be returned to the United States without further order of Court. All material
returned shall be segregated, kept under seal, and preserved by the United States for a period
of three years after sentencing or an earlier resolution of the charge(s) against the defendant.
Three years after the sentencing date, these materials will be destroyed by the United States.

2. All materials provided by the United States may be utilized by defendant and
his counsel solely in connection with the defense of this case and for no other purpose and
in connection with no other proceeding. The materials and their contents shall not be

disclosed either directly or indirectly to any person or entity other than defendant, defendant’s



counsel, persons employed to assist in the defense, or such other persons as to whom the
Court may authorize disclosure. Any notes or records of any kind that defense counsel or any
other recipient may make relating to the contents of materials provided by the government
shall not be disclosed to anyone other than the defendant, defense counsel, and persons
employed to assist in the defense, or such other person as to whom the Court may authorize
disclosure, and all such notes and records shall not be disclosed except as provided by this
Order.

3. The materials shall not be copied or reproduced by defense counsel or any
other recipient, except as necessary to provide copies of the materials for use by defense
counsel, defendant and such persons as are employed by them to assist in the defense. Such
copies and reproductions shall be treated in the same manner as the original matter.

4. Prior to providing or disclosing any of the materials to any recipient, defense
counsel shall provide a copy of this Order to each recipient and shall advise each recipient
that at the conclusion of this case, the materials must be returned to defense counsel. All
individuals and entities receiving these materials from defense counsel shall be subject to this
Order and shall not further disclose the materials or their contents except as permitted by this
Order or any further order of this Court. Defense counsel shall maintain a copy of this Order
that has been signed and dated by each recipient who received any materials subject to this

Order.


5. Violation of this Order may result in the imposition of civil and criminal
sanctions.

ENTER:

PMO

P. MICHAEL MAHONEY
DATE: a UNITED STATES vatisreanune E

Agreed and Jointly submitted by:

KRISTIN J.C. ENTE! DATE
Attorney for Latoya Shaunta Burrows

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SCOTT A. VERSEMAN DATE
Assistant United States Attorney