UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

UNITED STATES OF AMERICA

v.

DRO KHOLAMIAN

No. 20 CR 530 

Judge Manish S. Shah

PROTECTIVE ORDER GOVERNING DISCOVERY

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

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3. 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.

4. 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 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. 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. 

6. 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 

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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.

7. 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.

8. 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:

MANISH S. SHAH

District Court Judge 

United States District Court

Northern District of Illinois

Date: August 27, 2020

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