1

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

UNITED STATES OF AMERICA

v.

JOHN GARCIA, aka “John Adams,” 

aka “Michael Chapman,” aka “John 

Adamino,” 

MARILYN ROTHSCHILD, and

BRIAN GUSTAFSON

Case No.: 20 CR 474

Judge Manish S. Shah

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 
2

may be shown copies of the materials as necessary to prepare the defense, but may 

not retain copies without prior permission of the Court. 

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. 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 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 
3 

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

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.

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: 

Judge Manish S. Shah

United States District Court

Northern District of Illinois

Date: ______________________ July 8, 2021