UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 22-CR-20224-BLOOM

 

UNITED STATES OF AMERICA

 

v. 

ALAN LI, 

 a/k/a “Michael Chen,” 

Defendant. 

____________________________________/

PROTECTIVE ORDER REGULATING DISCLOSURE OF 

DISCOVERY AND SENSITIVE INFORMATION CONTAINED THEREIN

 THIS CAUSE is before the Court on the United States of America’s Motion for a Protective 

Order, ECF No. [22], regulating the disclosure of discovery and sensitive information contained 

therein to defense counsel in connection with the government’s discovery obligations. The Court 

finds good cause and it is: 

ORDERED AND ADJUDGED that the Motion is GRANTED. The government is 

authorized to disclose sensitive information in its possession that the government believes 

necessary to comply with the discovery obligations imposed by this Court. 

 The government shall mark that portion of the discovery that includes sensitive information 

as “Confidential”. 

 Counsel of record for the Defendant in this proceeding shall hold the Confidential portion 

of the discovery in strict confidence. Defense counsel shall restrict access to this discovery, and 

shall disclose this discovery to their client, office staff, investigators, and to anticipated fact or 

expert witnesses only to the extent that defense counsel believes is necessary to assist in the defense 

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CASE NO. 22-CR-20224-BLOOM

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of their client in this matter and in a manner that will prohibit the disclosure of this discovery to 

other persons not involved in the defense.

Counsel of record for the Defendant shall advise any person to whom the Confidential 

portion of the discovery is disclosed that such information shall be held in strict confidence, and 

that further disclosure or dissemination is prohibited without defense counsel’s express consent;.

The Defendant shall not maintain any copy of the Confidential portion of the Discovery at 

the Federal Detention Center or other jail facility without defense counsel present. Should the 

defendant wish to review any part of the Confidential portion of the Discovery without defense 

counsel present, upon request the Government shall provide a redacted copy of the particular 

document(s) requested.

Counsel of record for the Defendant shall obtain a certification from each person to whom 

the Confidential portion of the discovery is disclosed (excluding the Defendant), in which the 

recipient, (a) acknowledges these restrictions as set forth in the Protective Order of the Court, and 

(b) agrees that they will not disclose or disseminate the information without express consent of 

defense counsel. Counsel shall keep a copy of each certification to identify the individuals who 

received the Confidential portion of the discovery and the date on which such information was 

first disclosed. 

Counsel of record agree that, upon conclusion of the above captioned case,

1 copies of the 

Confidential portion of the discovery disclosed to defense counsel pursuant to the terms of this 

order shall be destroyed or returned to the United States. 

1 The conclusion of the case shall mean the period at the conclusion of any appellate and Section 

2255 proceedings, if any, or upon expiration of the deadline for filing appellate or Section 2255 

proceedings. 

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CASE NO. 22-CR-20224-BLOOM

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DONE AND ORDERED in Chambers, at Miami, Florida on August 2, 2022. 

_______________________________________

BETH BLOOM

UNITED STATES DISTRICT COURT JUDGE

cc: Counsel of record

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