UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

UNITED STATES OF AMERICA

v.

RAHUL SHAH

No. 20 CR 293

Magistrate Judge Maria Valdez

STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY

Upon the motion of the UNITED STATES and defendant RAHUL SHAH (collectively, 

the “parties”), pursuant to Fed. R. Crim. P. 16(d), it is hereby ORDERED:

1. This case involves records that contain social security numbers, home addresses, 

personal telephone numbers and similar types of private personal information about individuals 

not charged in this case (“personal private information”). In order to protect this personal private 

information, 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 SHAH and SHAH’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, except as provided 

below.

2. SHAH and SHAH’s counsel may use the materials without any of the restrictions 

present in this order if counsel redacts the record to be used or shared so that no personal private 

information remains in the record (except that the name may be left unredacted). Such a redacted 

record can be filed in Court without the need for sealing the record. For unredacted records that 

contain personal private information, SHAH and SHAH’s counsel shall not disclose such materials 

or their contents directly or indirectly to any person or entity other than (a) persons employed to 

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assist in the defense such as experts and consultants, the entities and the employees of those entities 

for which the PPP loans were submitted, (b) persons who are interviewed as potential witnesses,

(c) counsel for potential witnesses, (d) counsel in a joint defense agreement with SHAH’s counsel 

and their clients; and (e) other persons to whom the Court may authorize disclosure (collectively, 

“authorized persons”). Due to the COVID-19 pandemic and the need to maintain social-distancing, 

authorized persons may be provided with unredacted copies of the materials as necessary to 

prepare the defense, after they agree to be bound by the agreement to protect the personal private 

information attached hereto as Exhibit A. SHAH’s counsel shall maintain a copy of the signed 

Exhibit As and may, if required, file those executed Exhibit As with the Court under seal and in 

camera without serving the government with the filing.

3. SHAH, SHAH’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.

4. SHAH, SHAH’s 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, SHAH’s 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 the United States; or (3) retained in SHAH’s 

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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. 

7. To the extent any material is produced by the United States to SHAH or SHAH’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, SHAH and/or SHAH’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.

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 SHAH’s counsel in the use of discovery materials 

in representing their client in judicial proceedings in this case.

9. Nothing contained in this Order shall preclude any party to this Order from applying 

to this Court for further relief or for modification of any provision hereof.

ENTERED:

 

Honorable Maria Valdez

Magistrate Judge, United States District Court for the 

Northern District of Illinois

DATED: July 23, 2020

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Exhibit A in U.S. v. Shah

I, _____________________, have read the Court’s order and have received a copy of it. 

I agree to be bound by its terms. I understand that the materials I have received contain personal 

private information about persons other than me. I will not share, distribute or use any such 

personal private information. If I do, I can be held in contempt of court for violating the Court’s 

protective order in this case. When done with the materials I received in this case, I agree to 

destroy them or return them to counsel for Rahul Shah. I will provide a signed copy of this 

agreement to counsel for Rahul Shah.

_________________

Date

__________________

Printed Name

__________________

Signature

__________________

Address

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