IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION

UNITED STATES OF AMERICA 

v. 

SARGON AUDISHO 

No. 20 CR 558 

Judge John F. Kness 

PROTECTIVE ORDER GOVERNING DISCOVERY 

Upon the 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 Sargon 

Audisho (“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 

consulted, appointed or 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 they may not retain copies without prior 

permission of the Court. 

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3. Certain materials to be disclosed by the government contain 

particularly sensitive information, including medical records of persons other than 

the Defendant. These materials will be produced without redactions of the personal 

identifying and medical information, but they will be subject to the rules of this 

Order. These materials shall be plainly marked as sensitive by the government either 

on the face of the document or in an index accompanying the document’s production 

at the time of disclosure. Absent prior permission from the Court, information marked 

as sensitive shall not be included in any public filing with the Court, and instead shall 

be submitted under seal, with the permission of the Court (except if Defendant 

chooses to include in a public document sensitive information relating solely and 

directly to Defendant). 

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 

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. 

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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. 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 (with the Court’s permission), absent prior permission from this Court, 

unless the parties agree on appropriate redaction of sensitive information. 

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. 

SO ORDERED. 

 

Date: September 11, 2020 

 JOHN F. KNESS 

 United States District Judge 

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