UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

UNITED STATES OF AMERICA

No. 20 CR 232

Judge Ronald A. Guzman

v.

JAMES COLLINS, et al.

PROTECTIVE ORDER GOVERNING DISCOVERY

Upon the unopposed motion of the defendant James Collins, pursuant to Fed. R. 

Crim. P. 16(d), it is hereby ORDERED:

1. All of the materials provided by third party CIVC Partners, LP (“CIVC”) 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, counsel for the United States of America in this case, the Federal Bureau of 

Investigation, and other persons to whom the Court may authorize disclosure (collectively, 

“authorized persons”). Potential witnesses and their counsel may be shown copies of the 

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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 CIVC; or (3) retained in defense 

counsel's case file (and, if shared with counsel for the United States, retained in the case file 

of the United States Attorney’s Office). 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.

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7. To the extent any material is produced by CIVC to defendants or defendants’ 

counsel by mistake, CIVC 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: ________________________ 

RONALD A. GUZMAN

District Court Judge 

United States District Court Northern District of 

Illinois 

Date: July 14, 2022 

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