UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

UNITED STATES OF AMERICA

v.

YEN CHAM YUNG

No. 20 CR 231

Judge John Z. Lee

SUPPLEMENTAL PROTECTIVE ORDER GOVERNING DISCOVERY

Upon the unopposed motion of the government, pursuant to Federal Rule of 

Criminal Procedure 16(d), it is hereby ORDERED:

1. Consistent with the terms of Federal Rule of Criminal Procedure 16, the 

government previously provided certain discovery to defendants. Certain materials 

still to be disclosed by the government contain particularly sensitive information, the 

unrestricted dissemination of which could adversely affect the privacy and safety of 

third parties and governmental interests independent of this matter. This 

information consists of documents obtained from the defendant’s residences during 

the course of the investigation (the “Attorneys’-Eyes-Only Materials”). The 

Attorneys’-Eyes-Only Materials shall be plainly marked by the government prior to 

disclosure. For written materials, the pages that are Attorney’s-Eyes-Only will be 

individually marked. For other items, such as audio or video recordings, the media 

containing those recordings will be marked in the same manner.

2. Neither the Attorneys’-Eyes-Only Materials nor the information 

contained therein may be disclosed to any persons other than counsel for defendant

(defined as counsel of record in this case) or investigators employed by defendant’s
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counsel to assist the defense (“authorized persons”), without prior notice to the 

government and authorization from the Court. Absent prior permission from the 

Court, the Attorneys’-Eyes-Only Materials shall not be included in any public filing 

with the Court, and instead shall be submitted under seal.

3. Defendants’ counsel and authorized persons shall not copy or reproduce 

the Attorneys’-Eyes-Only Materials except for use in connection with this case by 

defendants’ counsel and authorized persons. Such copies and reproductions shall be 

treated in the same manner as the original materials.

4. 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 Attorneys’-

Eyes-Only Materials, and all such notes or records are to be treated in the same 

manner as the original materials.

5. Before providing the Attorneys’-Eyes-Only Materials to an authorized 

person, defense counsel must provide the authorized person with a copy of this Order 

and require the authorized person to sign a statement acknowledging that the 

authorized person has received a copy of and reviewed this Order, and has agreed to 

be bound by its terms and conditions subject to sanctioning by the Court for any 

violations of this Order. Defense counsel shall maintain a copy of the signed 

statement of each authorized person for a period of twelve months after the 

conclusion of all stages of this case and shall provide copies of the signed statement 

of all authorized persons to the government upon request.
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6. The defendant is authorized to review the Attorneys’-Eyes-Only 

Materials in the possession of defense counsel or other authorized persons but cannot 

retain or possess the material.

7. Upon conclusion of all stages of this case, all of the Attorneys’-Eyes-Only 

Materials and all copies made thereof shall be disposed of in one of three ways, unless 

otherwise ordered by the Court. The Attorneys’-Eyes-Only Materials may be 

(1) destroyed; (2) returned to the United States; or (3) retained in defense counsels’

case files. The Court may require a certification as to the disposition of any such 

Attorneys’-Eyes-Only Materials. In the event that the Attorneys’-Eyes-Only 

Materials are retained by defense counsel, the restrictions of this Order continue in 

effect for as long as the Attorneys’-Eyes-Only Materials are so maintained, and the 

Attorneys’-Eyes-Only Materials may not be disseminated or used in connection with 

any other matter without further order of the Court. 

8. To the extent any Attorneys’-Eyes-Only Materials are produced by the 

United States to defendant or defendants’ 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 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.

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 
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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 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: 5/25/21

JOHN Z. LEE

District Judge

United States District Court

Northern District of Illinois