PROTECTIVE ORDER as to Adedayo Ilori, Chris Recamier....regarding procedures to be… — USA v. Ilori et al (Dkt. 13)

Summary

A Protective Order, filed 12/22/21 as Document 13 in United States of America v. Adedayo Ilori and Chris Recamier, 21 Cr. 746 (MKV) (docket No. 1:21-cr-00746-MKV), in the U.S. District Court for the Southern District of New York. The order states that disclosure material shall be used by the defense solely for purposes of defending the action, and shall not be posted on any Internet site or disclosed to the media or any third party except as set forth. It permits disclosure to counsel's personnel and prospective witnesses, and addresses seized electronically stored information, return or destruction of material, and retention of jurisdiction. The consent block names Daniel G. Nessim, Peter Brill and Lorraine Gauli-Rufo, and the signature line for the Honorable Mary Kay Vyskocil is blank.

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
United States of America 
v. 
Adedayo Ilori and 
Chris Recamier, 
Defendants. 
Protective Order 
21 Cr. 746 (MKV) 
 
Upon the application of the United States of America, with the consent of the undersigned 
counsel, and the defendants having requested discovery under Fed. R. Crim. P. 16, the Court 
hereby finds and orders as follows: 
1. Disclosure Material. The Government will make disclosure to the defendant(s) of
documents, objects and information, including electronically stored information (“ESI”), pursuant 
to Federal Rule of Criminal Procedure 16, 18 U.S.C. § 3500, and the Government’s general 
obligation to produce exculpatory and impeachment material in criminal cases, all of which will 
be referred to herein as “disclosure material.” The Government’s disclosure material may include 
material that (i) affects the privacy and confidentiality of individuals; (ii) would impede, if 
prematurely disclosed, the Government’s ongoing investigation of uncharged individuals; (iii) 
would risk prejudicial pretrial publicity if publicly disseminated;  and (iv) that is not authorized to 
be disclosed to the public or disclosed beyond that which is necessary for the defense of this 
criminal case. 
12/22/2021
USDC SDNY 
DOCUMENT 
ELECTRONICALLY FILED 
DOC #: 
 
 
 
DATE FILED: 
 
 
Case 1:21-cr-00746-MKV     Document 13     Filed 12/22/21     Page 1 of 5

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NOW, THEREFORE, FOR GOOD CAUSE SHOWN, IT IS HEREBY ORDERED: 
 
 
2. Disclosure material shall not be disclosed by the defendant or defense counsel, including 
any successor counsel (“the defense”) other than as set forth herein, and shall be used by the 
defense solely for purposes of defending this action. The defense shall not post any disclosure 
material on any Internet site or network site to which persons other than the parties hereto have 
access, and shall not disclose any disclosure material to the media or any third party except as set 
forth below. 
 
 
3. Disclosure material may be disclosed by counsel to: 
 
 
 
(a) Personnel for whose conduct counsel is responsible, i.e., personnel employed by or 
retained by counsel, as needed for purposes of defending this action; 
 
 
 
(b) Prospective witnesses for purposes of defending this action.  
 
 
4. The Government may authorize, in writing, disclosure of disclosure material beyond that 
otherwise permitted by this Order without further Order of this Court.  
 
 
5. This Order does not prevent the disclosure of any disclosure material in any hearing or 
trial held in this action, or to any judge or magistrate judge, for purposes of this action. All filings 
should comply with the privacy protection provisions of Fed. R. Crim. P. 49.1. 
 
 
6. The Government has advised that information that may be subject to disclosure in this 
case may be contained within ESI that the Government has seized, pursuant to warrants issued 
during the course of the investigation, from various computers, cell phones, and other devices and 
storage media. This ESI was seized from Adedayo Ilori and Chris Recamier:  Upon consent of all 
counsel, the Government is authorized to disclose to counsel for the defendants, for use solely as 
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permitted herein, the entirety of such seized ESI as the Government believes may contain 
disclosure material (“the seized ESI disclosure material”).  Defense counsel, and personnel for 
whose conduct counsel is responsible, i.e., personnel employed by or retained by counsel, may 
review the seized ESI disclosure material to identify items pertinent to the defense. They shall not 
further disseminate or disclose any portion of the seized ESI disclosure material except as 
otherwise set forth under this Order. 
7. Except for disclosure material that has been made part of the record of this case, the
defense shall return to the Government or securely destroy or delete all disclosure material, 
including the seized ESI disclosure material, within 30 days of the expiration of the period for 
direct appeal from any verdict in the above-captioned case; the period of direct appeal from any 
order dismissing any of the charges in the above-captioned case; or the granting of any motion 
made on behalf of the Government dismissing any charges in the above-captioned case, whichever 
date is later. If disclosure material is provided to any prospective witnesses, counsel shall make 
reasonable efforts to seek the return or destruction of such materials. 
8. The defense shall provide a copy of this Order to prospective witnesses and persons
retained by counsel to whom the defense has disclosed disclosure material or the Government’s 
ESI production. All such persons shall be subject to the terms of this Order. Defense counsel shall 
maintain a record of what information has been disclosed to which such persons. 
9. This Order places no restriction on a defendant’s use or disclosure of ESI that originally
belonged to the defendant. 
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 Retention of Jurisdiction 
10. The provisions of this order shall not terminate at the conclusion of this criminal
prosecution and the Court will retain jurisdiction to enforce this Order following termination of 
the case. 
AGREED AND CONSENTED TO: 
DAMIAN WILLIAMS 
United States Attorney 
by: _____________________________ 
Date: _12/15/2021___________ 
Daniel G. Nessim 
Assistant United States Attorney 
___________________________ 
Date: _____________________ 
Peter Brill 
Counsel for Adedayo Ilori 
___________________________ 
Date: _____________________ 
Lorraine Gauli-Rufo 
Counsel for Chris Recamier 
SO ORDERED: 
Dated: New York, New York  
December __, 2021 
_______________________________________ 
THE HONORABLE MARY KAY VYSKOCIL 
UNITED STATES DISTRICT JUDGE 
12/15/2021
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