UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

EUGENE DIVISION 

UNITED STATES OF AMERICA Case No. 05-cr-60008-02-HO 

v. 

PIROUZ SEDAGHATY, 

Defendant. 

" In, I) PROTECTIVE ORDER 

PERTAINING TO CLASSIFIED 

INFORMATION 

This matter is bef ore the Court upon the Governrnent' s Motion for a Protective Order 

Pertaining to CIassified Information to prevent the unauthorized disc10sure or dissemination of 

c1assified national security information and documents which may be reviewed by or made availabie 

to counsel for the defendant in this case. 

Section 3 of the Classified Information Procedures Act, 18 U.s.C. App. 3 ("CIPA"), requires 

entry of a protective order upon motion by the governrnent. The governrnent has moved for an order 

to protect against the disc10sure of classified information to be disclosed by the United States to 

defense counsel in this case. 

Pursuant to the authority granted under Section 3 of CIP A; the Security Procedures 

Established Pursuant to Pub. L. 96-456,94 Stat. 2025, by the Chief Justice of the United States for 

the Protection of CIassified Information (reprinted following Section 9 of CIPA) ("Security 

Procedures"); Rule 16(d) of the Federal Rules of Criminal Procedure; the general supervisory 

authority of the Court; and in order to protect the national security, 
THE COURT HEREBY FINDS AND ORDERS: 

1. By order dated February 26, 2010 (CR 278), the Court authorized the govemment 

to provide a cIassified summary of certain specific cIassified national security infonnation to defense 

counsel. This case will therefore involve classified national security infonnation, the storage, 

handling and control ofwhich, by law orregulation, requires special security precautions, and access 

to which requires a security clearance and an actual need to know. 

2. The purpose of this Order is to establish the procedures that must be followed by 

defense counsel, other counsel involved in this case, persons assisting defense counsel, other Court 

personnel, and all other individuals who are granted access to classified infonnation or documents 

in connection with this case. It is a further purpose of this Order to ensure that those authorized by 

the Order to receive classified infonnation do not divulge the classified infonnation disclosed to 

them to anyone who is not authorized to receive it, or otherwise use the classified infonnation, 

except in confonnity with this Order or with priorwritten authorization from the originating agency. 

3. The procedures set forth in this Protective Order and in CIP A will apply to all 

pretrial, trial, post-trial and appellate aspects concerning classified infonnation in this case, and may 

be modified from time to time by further order of the Court acting pursuant to Fed. R. Crim. P. 

16( d), CIP A, and the Court' s inherent supervisory authority to ensure a fair trial. 

4. Definitions. The following definitions shall apply to this Order: 

a. The tenns "classified national security infonnation and documents," 

"classified documents and infonnation," "classified infonnation," and "classified documents" refer 

to: 

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['l!!fJIi-atJll Protective Order Pertaining to C1assified Information Page 2 
i. Any document that has been classified by any Executive Branch 

agency in the interests of national security or pursuant to Executive Order 12958, as amended, as 

"CONFIDENTIAL," "SECRET," or "TOP SECRET," or additionally controlled as "SENSITIVE 

COMPAR TMENTED INFORMATION" (SCI), and any information contained in such documents; 

ii. Any document or information that the defendant or the defense know, 

or should reasonably know, has been derived from United States goverument information that was 

cIassified, regardless whether such document or information has subsequentiy been classified by the 

goverument pursuant to Executive Order 12958 as amended; 

iii. Verbal cIassified information that has been discIosed by attomeys for 

the goverument or by a witness in a court proceeding to the defendant or the defense; or 

iv. Any document or information, including verbal information and 

"foreign goverument information" (as that term is defined in Executive Order 12958, as amended), 

that the defendant or the defense has been notified is classified, unless already possessed by or 

known to the defendant or the defense, provided that such knowledge is not derived from materials 

described in subparagraph 5(a)(i),(ii), or (iii) above. 

b. The words "document" and "information" shall include, but are not limited 

to, all written or printed matter of any kind, formal or informal, incIuding originals, conforming 

copies and non-conforming copies (whether different from the original by reason of notation made 

on such copies or otherwise), and further incIude, but are not limited to: 

i. Papers; correspondence; memoranda; notes; letters; reports, 

summaries; interoffice and intra-office communications; notations of any sort concerning 

conversations, meetings or other communications; bulletins; telexes; cables; teletypes; telegrams; 

[P'UI' II ~I Protective Order Pertaining to C1assified Information Page 3 
facsimiles; e-mails; invoices; worksheets; and drafts, alterations, modifications, changes and 

amendments of any kind to the foregoing; 

ii. Graphic or oral records or representations of any kind, including, but 

not limited to, photographs, maps, charts, graphs, microfiche, microfilm, videotapes, sound 

recordings of any kind and motion pictures; 

iii. Electronic, mechanical, magnetic, opticalor electric records of any 

kind, including, but not limited to, data stored on tapes, cassettes, CD-ROMS, disks, recordings, 

films, typewriter ribbons, word processing or other computer tapes or disks, and all manner of 

electronic data processing storage; and 

iv. Information acquired aurally. 

c. "Access to classified information" means having access to, reviewing, 

reading, learning, or otherwise coming to know in any manner any classified information. 

d. "Secure area" shall mean a physical facility accredited for the storage, 

handling, and control of classified information. 

e. "The defense" means anyperson assisting the defendant with the preparation 

of his defense in this case including (but not limited to) counsel for the defendant and employees 

of, consultants to or contractors for defense counsel. 

f. "Attorneys for the govemment," "govemment counsel," and "counsel for the 

govemment" means the attorneys listed in paragraph 9. 

g. "Originating agency" means the govemment agency, department or entity 

from which the cIassified document or the information contained therein originated. 

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[RI 91 I Ill] Protective Order Pertainlng to Classified Information Page 4 
5. Any document or information provided by attomeys for the govemment to the 

defense referencing, mentioning, originating from, or concerning any agency, or part of an agency, 

that is a member of the United States "intelligence community" (as defined in Section 3.4 of the 

National Security Act ofI947, coclified at 50 U.S.e. § 401a(4)), other than the FBI, or information 

in possession of such agency, or part thereof, other than the FBI, shall be presumed to fall within 

the meaning of c1assified information unless and untiI the Court Security Officer or an attomey for 

the govemment advises otherwise in writing. 

6. All c1assified documents and information shall remain c1assified unless such 

document or information bears a clear indication that it has been dec1assified by the originating 

agency. 

7. Information in the public domain is ordinarily not c1assified. However, such 

information may be considered classified, and therefore subject to the provisions of CIP A, if it is 

confirmed by any person who has had access to the cIassified information, and that confirmation 

corroborated the information in question. Any attempt by the defendant or the defense to have such 

information confirmed or denied at trial, or in connection with any pretrial, post-trial or other 

proceeding in this case, shall be govemed by CIP A and the provisions of this Order. 

8. In accordance with the provisions of CIP A and the Security Procedures, the Court 

designates Security Specialist Winfield S. "Scooter" Slade as Court Security Officer for this case 

and Security Specialists John D. Arszulowicz, Jennifer H. Campbell, Miguel A. Ferrer, Christine 

E. Gunning, DanielO. Hartenstine, Joan B. Kennedy, Michael P. Macisso, and Maura P. Peterson 

as Alternate Court Security Officers (collectively "the CSO"), for the purpose of providing security 

arrangements necessary to protect from unauthorized disclosure any c1assified documents or 

[P,III' ",'I Protective Order Pertaining to CIassified Information PageS 
infonnation to be made available in connectionwith this case. The defense shall seek guidance from 

the CSO with regard to the appropriate storage, handling, transmittal, and use of c1assified 

infonnation. 

9. The Court has been advised that the following govemment attomeys will be working 

on this case: Assistant United States Attomeys Charles F. Gorder, Jr. and Christopher 1. Cardani, 

along with various supervisory attomeys and other attomeys specifically designated in the United 

States Attomey's Office, District of Oregon. The Court has also been advised that the govemment 

attomeys have the requisite security clearanees to have access to the classified infonnation which 

is the subject of the Court's Order ofFebruary 26,2010 (CR 278) in this case. The govemment may 

add additional attomeys with notice to the Court and defense counsel. 

10. Protection ofClassified Documents and Infonnation: The Court finds that, in order 

to protect the classified documents and information involved in this case, no person except the 

attomeys for the govermnent, personnel of the originating agency and other intelligence agencies, 

appropriately-cleared Department of Justice employees, judicial personnel, and members of the 

defense, shall have access to the classified documents and infonnation in this case. 

a. Judicial personnel, other than the Court, may obtain access to classified 

documents or infonnation after having been granted security clearance by the CSO. 

b. No member ofthe defense shall have access to any classified documents or 

infonnation in this case unless that person shall first have: 

i. received approval for access to the particular classified documents or 

infonnation from the govemment or, should the govemment reject the request, from the Court in a 

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[PI ii neil) Protective Order Pertaining to Classified Information Page 6 
separate order, which shall not occur except upon a showing of a need to know the particular 

classified infonnation and upon consideration of any responsive pleading from the govemment; 

ii. received the necessary security clearance at the appropriate levél of 

classification as detennined by the Department of Justice Security Officer working in conjunction 

with the eso; and 

iii. signed a Memorandum ofUnderstanding (a fonn for which is attached 

hereto), agreeing to comply with the tenns of this Order. 

c. Subject to the provisions of subparagraph b above, the following attomeys 

for the defendant shall be given access to classified documents and infonnation as required by the 

govemment's discovery obligations and otherwise as necessary to prepare for proceedings in this 

case: Steven T. Wax, Lawrence Matasar, and William Teesda!e. 

d. Any additional person whose assistance the defense reasonably requires may 

only have access to classified infonnation in this case after obtaining from the Court-with prior 

notice to the government-an approval for access to the appropriate level of cJassification on a needto-know basis, and after satisfYing the other requirements described in this Order for access to 

c1assified infonnation. The substitution, departure, or removal for any reason from this case of 

defense counselor anyone associated with the defense as an employee or otherwise, shall not release 

that person from the provisions of this Order or the Memorandum ofUnderstanding executed in 

connection with this Order. 

e. The substitution, departure or removal of counsel for the defense or anyone 

associated with the defense as an employee, consultant, contractor, witness or otherwise shall not 

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[J'!lp9sedJ Protective Order Pertaining to Classified Information Page 7 
release that person from the provisions ofthis Order or the Memorandum ofUnderstanding executed 

in connection with this Order. 

f. The defendant shall not have access to any c1assified documents or 

information in this case. 

11. For the purpose of establishing the security clearanees necessary for access to 

classified documents and information that may be involved in this case, the defense, and such Court 

personnel as the Court requires for its assistance shall forthwith complete and submit to the CSO 

Standard Form 86 ("Security Investigation Data for Sensitive Position"), the necessaryreleases, and 

full fingerprints, unless such person already holds an appropriate security clearance and is approved 

for access to c1assified documents and information in this case. The CSO shall take all reasonable 

steps to process all security clearance applications in a timely manner. The CSO shall not disc10se 

to govemment attomeys any information supplied by anyone applying for security clearance 

pursuant to this Order. 

12. The CSO shall arrange for and maintain an appropriately approved secure area for 

the use of the defense. The CSO shall establish procedures to ensure that the secure area is 

accessible during normal business hours, and at other times on reasonable request as approved by 

the CSO, to the defense. The secure area will be outfitted with any secure office equipment 

requested by the defense that is reasonable and necessary to the preparation of a defense in this case. 

The CSO, in consultation with defense counsel, shall establish procedures to assure that the secure 

area may be maintained and operated in the most efficient manner consistent with the protection of 

c1assified information. No documents containing c1assified information may be removed from the 

secure area by anyone, inc1uding the defense, unless authorized by the CSO. No person, including 

[lh ap 1.11) Protective Order Pertaining to Classified Information PageS 
the defense, shall copy orreproduce any c1assified document orinfol1llation in any fOl1ll, except with 

the approval of the CSO or in accordance with the procedures established by the CSO for the 

operation of the secure area. 

13. Filing of Papers by the Defense: Any pleading or other document filed by the 

defense that contains c1assified infol1llation or infol1llation that is reasonably believed to be 

c1assified shall be filed under seal with the Court through the CSO or his designee. Pleadings filed 

under seal with the CSO shall be marked, "Filed In Camera and Under Seal with the Court Security 

Officer or Designee." Such pleadings need not be accompanied by a separate motion to seal, but 

should inc1ude in the introductory paragraph a statement that the item is being filed under seal 

pursuant to this Order. At the time of making a physical submission to the Court Security Officer 

or designee, counsel shall file on the public record in the CMIECF system a notice of filing that 

notifies the Court that a filing has been made. The CSO shall promptly examine the pleading or 

document and, in consultation with representatives of the appropriate agencies, detel1lline whether 

the pleading or document contains classified information. lf the CSO determines that the pleading 

or document contains c1assified infol1llation, he sha1l ensure that the portion of the document that 

contains c1assified infol1llation, and only that portion, is marked with the appropriate classification 

marking( s) and remains under seal. Any papers filed by the defense that do not contain any 

c1assified infol1llation sha1l be immediately unsealed by the CSO and plaeed in the public record. 

The CSO sha1l immediately deliver under seal to the Court and attomeys for the govemment any 

pleading or document filed by the defense that contains classified infol1llation. 

14. Filing of Papers by the Govemment: Any pleading or document filed by attomeys 

for the govemment that contains c1assified infol1llation shall be filed under seal with the Court 

[i. Iiliiml] Protective Order Pertaining to Classified Information Page 9 
through the CSO or his designee. Such pleadings and documents shall be marked, "Filed In Camera 

and Under Seal with the Court Security Officer or Designee." Such pleadings need not be 

accompanied by a separate motion to seal, but should incIude in the introductory paragraph a 

statement that the item is being filed under seal pursuant to this Order. At the time of making a 

physical submission to the Court Security Officer or designee, counsel shall file on the public record 

in the CM/ECF system a notice of filing that notifies the Court that a filing has been made. The time 

of physical submission to the CSO shall be considered that date and time of filing or as otherwise 

determined by the CSO. The CSO shall immediately deliver under seal to the Court and the defense 

(unless such filing is an ex parte filing) any pleading or document filed by the govemment that 

contains cIassified information, provided that the defense has proper clearance and need-to-know 

to receive the pleading or document. 

15. Sealing of Records: The CSO shall maintain a separate sealed record for those 

pleadings or documents containing cIassified materials. The CSO shall be responsible for 

maintaining the secured records for purposes of later proceedings or appeal. 

16. Access to Classified Information: The defense shall have access to classified 

documents or information only as follows: 

a. All classified documents or information produced by the government to the 

defense, in discovery or otherwise, and all cIassified documents or information possessed, created, 

or maintained by the defense, shall be stored, maintained, and used only in the secure area 

established by the CSO or in another area authorized by the CSO. 

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I' i .J) Protective Order Pertaining to Classifled Information Page 10 
b. The defense shall have free access in the secure area to the classified 

documents or information made available to them in accordance with this Order, and shall be 

aIiowed to take notes and prepare documents with respect to those materiais. 

c. All documents prepared by the defense (including pleadings or other 

documents intended for filing with the eourt) that contain or deal in any way with classified 

information shall be transcribed, recorded, typed, duplicated, copied, and otherwise prepared only 

by persons who have received an appropriate approval for access to classified information, and only 

in the secure area on approved word processing and data handling equipment, and in accordance 

with the procedures approved by the eso. All such documents and any associated materials (such 

as notes, drafts, copies, typewriter ribbons, magnetic recordings, and exhibits) containing classified 

information shall be maintained in the secure area unless and until the eso determines that those 

documents or associated materials are unclassified in their entirety. None of these materials shall 

be disclosed to counsel for the government. 

d. The defense shall discuss classified documents or information only within the 

secure area or in another area authorized by the eso, and shall not discuss or attempt to discuss 

classified information over any standard commercial telecommunications system or office 

communication system, including, but not limited to, by facsimile and over the internet. 

e. The eso shall not reveal to the government or the Court the content of any 

conversation he may hear among the defense, reveal the nature of the documents being reviewed by 

them, or the work generated by them. In addition, the presence of the eso shall not operate as a 

waiver of, limit, or otherwise render inapplicable, the attorney-client or work product privilege. 

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[II!I!&ifBIllldl] Protective Order Pertaining to C1assified Information Page 11 
17. DiscIosure of Classified Infonnation: The defense shall not disclose, without prior 

approval of the Court, any classified document or infonnation to any person not authorized pursuant 

to this Order, except for the Court or those Court persormel, persormel of the originating agency and 

otherintelligence agencies, appropriately-cleared Department ofJustice employees, or attomeys for 

the govemment who have been identified by the CSO as having the appropriate clearances and the 

need-to-know and in accordance with the procedures ofCIPA and the procedures established by the 

CSO. Counsel for the govemment shall be given an opportunity to be heard in response to any 

defense request for disclosure to a person not named in this Order. Any person approved by the 

Court for disclosure under this paragraph shall be required to obtain the appropriate security 

clearance, to sign and submit to the Court a Memorandum ofUnderstanding in the fonn attached 

to this Order, and to comply with all tenns and conditions of this Order. If preparation of the 

defense requires that classified documents or infonnation be discIosed to a person not named in this 

Order, the CSO shall promptly seek to obtain a security clearance for such person at the request of 

defense counsel. 

a. No person shall discuss c1assified documents or infonnation in the presence 

of any person who has not been granted access by the Court to such c1assified docurnents or 

infonnation. 

b. No person shall disclose c1assified docurnents or infonnation to the defendant. 

c. Procedures for the use or the public disclosure of c1assified infonnation shall 

be those provided in Sections 5, 6 and 8 of CIP A. These provisions, and this Order, require that: 

I. Anyand all items which are c1assified that the defense seeks to use 

shall be listed in the defendant' s Section 5 notices. 

[Pr 9J19SCdJ Protective Order Pertaining to Classified Information Page 12 
ii. To facilitate the filing of notices required under Section 5 of CIPA, 

the CSO shall make arrangements with the appropriate agencies for a determination of the 

c1assification level, ifany, ofmaterials or information either within the possession of the defense 

or about which the defense has knowledge and which the defense intends to use in any way at any 

pretrial proceeding, deposition, trial or post-trial or other proceeding. Nothing submitted by the 

defense to the CSO pursuant to this paragraph shall be made available to counsel for the government 

unless so ordered by the Court or so designated by the defense. 

18. Any unauthorized use or disc10sure of classified information may constitute a 

violation of United States criminal law. In addition, any violation of the terms of this Order shall 

be immediately brought to the attention of the Court and may resuit in a charge of contempt of the 

Court and possible referral for criminal prosecution. Any breach of this Order mayalso resuit in the 

termination of the person ' s access to c1assified documents and information. Persons subject to this 

Order are advised that direct or indirect unauthorized use, disc1osure, retention ornegligent handling 

of classified documents or information could cause serious damage, and in some cases exceptionally 

grave damage, to the national security of the United States and may be used to the advantage of a 

foreign power against the interests of the United States. 

19. All classified documents and information to which the defense has access in this case 

are now and forever remain the property of the govemment. Any member of the defense who 

receives c1assified documents or information shall return all such documents and information in their 

possession or for which they are responsible, upon demand of the CSO. Any notes, summaries, or 

other documents prepared by the defense that contain classified information shall remain at all times 

in the custody of the CSO for the duration of this case. All such notes, sununaries, and other 

[I!: oposcd] Protective Order Pertaining to C1assified Information Page 13 
documents sha11 be destroyed by the CSO in the presence of defense counsel, should they choose 

to be present, (a) one year afterthejudgment in this case is final or (b) at the conc1usionoflitigation 

(including appeals) ofany motion filed pursuant to 28 U.S.C. § 2255, ifsaid motion was filed within 

one year after the judgment became final, whichever event is later. 

20. A copy of this Order shall be issued to the attomeys for the govemment, the CSO, 

and counsel of record for the defendant. Counsel for the defense shall be responsible for advising 

any other member of the defense who should be made aware of the contents of this Order. Counsel 

for the defendant and any other individuals who will be provided access to cIassified documents or 

information pursuant to this Order shall execute the Memorandum ofUnderstanding in the form 

attaehed hereto. Counsel for the defendant shall file exeeuted originaIs of sueh documents with the 

Court, and serve copies of executed originals of such documents upon the CSO and the govemment. 

The execution and filing of the Memorandum ofUnderstanding is a condition precedent for any 

member of the defense or any other individual to have access to classified information. 

21. This Protective Order is not intended to modify, amend, or supersede the Court's 

Order ofMay 16,2008 (CR 103) which remains in full force and effect until further order of this 

or another Court. In addition, this Protective Order does not cover any aspects of access to or use 

of the material subject to the Order of May 16, 2008. Should that Order be changed, a new 

Protective Order addressing that material will be required before the defense can communicate, 

review the material, or prepare any pleadings. 

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['" pw. "I] Protective Order Pertainlng to CIassified Information Page 14 
Case 6:05-cr-60008-HO Document 294-2 Filed 03/18/2010 Page 15 of 21 

22. The Court may amend this Protective Order andlor issue additional Protective Orders 

as needed. 

Dated this ~ay of...::....;--+-=..::::....;:::=---4..,2010. 

Presented by: 

DWIGHT C. HOLTON, OSB #09054 

United States Attomey 

District of Oregon 

Is! Charles F. Gorder. Jr. 

CHARLES F. GORDER, JR., OSB #91287 

Assistant United States Attomey 

Isl Christopher L. Cardani 

CHRISTOPHER L. CARDANI 

Assistant United States Attomey 

[fl.p lidI Protective Order Pertaining to Classified Information Page 15 
UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

EUGENE DIVISION 

UNITED STATES OF AMERICA Case No. 05-cr-60008-02-HO 

V. 

PIROUZ SEDAGHATY, 

Defendant. 

MEMORANDUM OF 

UNDERSTANDING 

1. Having familiarizedmyselfwith the applicable laws, I understand that I have already 

received, and may be the future recipient of information and docurnents, that pertain to the national 

security of the United States, and which are the property of the United States, and that such 

docurnents and information, together with the methods of collecting such information, are c1assified 

according to security standards set by the United States government. 

2. I agree that I shall never divulge, publish or reveal, either by word, conduct or any 

other means, such c1assified information and docurnents unless specifically authorized to do so in 

writing by an authorized representative of the United States government, or as required by the 

Classified Information Procedures Act, or as otherwise ordered by this Court. 

3. I understand that this agreement will remain binding upon me after the conclusion 

of trial in United States v. Pirouz Sedaghaty, Criminal Case No. 05-cr-60008-02-HO, and any 

subsequent related proceedings including the appellate process. 
4. I have received, read and understand the Protective Order entered by the United 

States District Court for the District ofOregon in the above-styled case, and I agree to comply with 

the provisions contained therein. 

I deciare under penalty ofpeIjury under the laws of the United States that the foregoing is 

true and correct to the best of my knowiedge, information and belief. 

STEVEN T. W AX 

Counsel for Defendant Pirouz Sedaghaty 

Date 

Witness Name 

Witness Signature 

Memorandum ofUnderstanding Page 2 
UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

EUGENE DIVISION 

UNITED STATES OF AMERICA Case No. 05-cr-60008-02-HO 

v. 

PIROUZ SEDAGHATY, 

Defendant. 

MEMORANDUM OF 

UNDERSTANDING 

1. Having familiarized myselfwith the applicable laws, I understand that I have already 

received, and may be the future recipient of information and documents, that pertain to the national 

security of the United States, and which are the property of the United States, and that such 

documents and information, together with the methods of collecting such information, are classified 

according to security standards set by the United States govermnent. 

2. I agree that I shall never divulge, publish or revea!, either by word, conduct or any 

other means, such classified information and documents unless specifically authorized to do so in 

writing by an authorized representative of the United States govermnent, or as required by the 

Classified Information Procedures Act, or as otherwise ordered by this Court. 

3. I understand that this agreement will remain binding upon me after the conclusion 

of trial in United States v. Pirouz Sedaghaty, Criminal Case No. OS-cr-60008-02-HO, and any 

subsequent related proceedings including the appellate process. 
4. I have received, read and understand the Protective Order entered by the United 

States District Court for the District ofOregon in the above-styled case, and I agree to comply with 

the pro visions contained therein. 

I deciare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct to the best of my knowiedge, information and belief. 

LA WRENCE MATASAR 

Counsel for Defendant Pirouz Sedaghaty 

Date 

Witness Name 

Witness Signature 

Memorandum of Understanding Page 2 
UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

EUGENE DIVISION 

UNITED STATES OF AMERICA Case No. OS-cr-60008-02-HO 

v. 

PIROUZ SEDAGHATY, 

Defendant. 

MEMORANDUM OF 

UNDERST ANDING 

I. Having familiarizedmyselfwith the applicable laws, I understand that I have already 

received, and may be the future recipient of information and documents, that pertain to the national 

security of the United States, and which are the property of the United States, and that such 

documents and information, together with the methods of collecting such information, are c1assified 

according to security standards set by the United States govermnent. 

2. I agree that I shall never divulge, publish or reveal, either by word, conduct or any 

other means, such classified information and documents unless specifically authorized to do so in 

writing by an authorized representative of the United States government, or as required by the 

Classified Information Procedures Act, or as otherwise ordered by this Court. 

3. I understand that this agreement will remain binding upon me after the conc1usion 

of trial in United States v. Pirouz Sedaghaty, Criminal Case No. 05-cr-60008-02-HO, and any 

subsequent related proceedings inc1uding the appellate process. 
4. I have received, read and understand the Protective Order entered by the United 

States District Court for the District ofOregon in the above-styled case, and I agree to comply with 

the provisions contained therein. 

I deciare under penalty of peIjury under the laws of the United States that the foregoing is 

true and correct to the best ofmy knowIedge, information and belief. 

WILLIAM TEESDALE 

ChiefInvestigator for Counsel for 

Defendant Pirouz Sedaghaty 

Date 

Witness Name 

Witness Signature 

Memorandum of Understanding Page 2