UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

WESTERN DIVISION 

UNITED STATES OF AMERICA 

v. 

MICHAEL ALEXANDER 

No. 20 CR 50004 

Judge Lisa A. Jensen 

PROTECTIVE ORDER GOVERNING DISCOVERY 

Upon the agreed motion of the government, pursuant to Fed. R. Crim. P. 16(d) 

and 18 U.S.C. § 3771(a)(1) and (8), 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 defendant and 

defendant’s 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. Defendant and defendant’s 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. The materials and their 
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contents shall not be disclosed either directly or indirectly to any person or entity 

outside of the United States without prior authorization from the Court. 

3. Certain materials disclosed or to be disclosed by the government may 

contain particularly sensitive information, including financial information of one or 

more persons other than the defendant to whom the information is disclosed. No such 

materials, or the information contained therein, may be disclosed to any persons 

other than defendant, counsel for defendant, persons employed to assist the defense, 

or the person to whom the sensitive information solely and directly pertains, without 

prior notice to the government and authorization from the Court. Absent prior 

permission from the Court, financial sensitive information shall not be included in 

any public filing with the Court, and instead shall be submitted under seal (except in 

the case of a defendant who chooses to include in a public document sensitive 

information relating solely and directly to the defendant making the filing). 

4. Defendant, defendant’s 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 defendant, defendant’s counsel, and authorized 

persons. Such copies and reproductions shall be treated in the same manner as the 

original materials. 

5. Defendant, defendant’s counsel, and authorized persons shall not 

disclose any notes or records of any kind that they make in relation to the contents of 
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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. 

6. Before providing materials to an authorized person, defense counsel 

must provide the authorized person with a copy of this Order. 

7. 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. 

8. To the extent any material is produced by the United States to 

defendant or defendant’s 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, defendant and/or defendant’s 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. 
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9. 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, except 

that any document filed by any party which attaches or otherwise discloses specially 

identified sensitive information as described in Paragraph 3, above, shall be filed 

under seal to the extent necessary to protect such information, absent prior 

permission from this Court. 

10. 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: 

 

LISA A. JENSEN 

Magistrate Judge 

United States District Court 

Northern District of Illinois 

Date: 

Agreed and Jointly submitted by: 

/s/ Anthony Peska 3/16/2019 

ANTHONY PESKA DATE 

Attorney for Michael Alexander 

/s/ Vincenza L. Tomlinson 3/16/2019 

VINCENZA L. TOMLINSON DATE 

Assistant United States Attorney 

3/17/2020