Text of Proposed Order — USA v. Ebrahimzadeh (Dkt. 28.1)

Record facts

U.S. District Court for the District of Massachusetts · No. 1:25-cr-10455-RGS · Doc. 28-1 · 2026-01-14 · Docket on CourtListener

Full text

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UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 
_______________________________________ 
 
 
UNITED STATES OF AMERICA 
 
 
 
v. 
 
DAVID EBRAHIMZADEH 
 
 
                                          
 
 
Criminal No. 25-cr-10455-RGS 
 
 
[PROPOSED] PROTECTIVE ORDER 
 
Upon consideration of the government’s Assented-To Motion for a Protective Order, and 
pursuant to Federal Rule of Criminal Procedure 16(d), it is hereby ORDERED that: 
1) 
The discovery materials produced by the government in this case may be used by the 
defendant, defendant’s counsel and their office staff (the “defense team”), and any experts or 
employees or agents of defendant’s counsel solely in defense of this case, including any appeal, 
and for no other purpose and in connection with no other proceeding.  
2) 
The defendant and defense team shall not disclose any discovery materials, directly 
or indirectly, to any other person except those assisting in the defense of the case, persons who are 
interviewed as potential witnesses, or potential experts employed during the course of and as 
necessitated by the investigation and defense of this case.  
3) 
Except in the case of expert witnesses, copies of discovery materials may only be 
shown to or played for, but not given to, potential witnesses.  
4) 
The government may designate as confidential certain materials it produces in 
discovery, whether pursuant to the Federal Rules, the Local Rules, or on a voluntary basis, which 
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materials contain particularly personal or sensitive information regarding an individual or entity, 
the dissemination of which could pose a serious risk of harm to any individual or entity or obstruct 
the government’s ongoing investigation (hereafter referred to as “Confidential Discovery 
Materials”). 
5) 
To designate discovery materials as Confidential Discovery Materials, the 
government will label the document (or, in the case of audio/video recordings, the filename and/or 
the storage media upon which it is stored) “Confidential.”  
6) 
The defense team shall maintain any discovery materials marked confidential by the 
government (“the Confidential Discovery Materials”), including any copies the defense makes, as 
follows: 
a) 
Except as provided below, the defense team shall maintain possession of all 
copies of the Confidential Discovery Materials. No copy may be left in the 
possession of the defendant, nor may the defendant write down, photograph, 
or otherwise record the content of the Confidential Discovery Materials.  
b) 
Only the defense team, the defendant, and any experts or other trial 
preparation professionals (“defense professionals”) designated by the 
defense team may view the Confidential Discovery Materials.  The 
defendant may access and view the Confidential Discovery Materials solely 
in the presence of the defense team (defense counsel or their office staff) 
and under the direct supervision and control of the defense team.  
c) 
In no event shall the defense team or the defendant disclose or describe any 
of the Confidential Discovery Materials to any other person or entity other 
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than the government or this Court, other than under the terms laid out below, 
or as necessary during a court proceeding, subject to redactions protecting 
confidential information or under seal after seeking permission in 
accordance with the Federal Rules of Criminal Procedure and this Court’s 
Local Rules. 
7) 
The defense team and the defendant may describe or provide copies of the 
Confidential Discovery Materials to any defense professional retained by them, but only if: 
a) 
The defense professional signs a copy of this Order, and by doing so, agrees 
to maintain the Confidential Discovery Materials in accordance with the 
above procedures as if they were members of the defense team and solely 
for the purposes of assisting the defense in this case, and not for any 
commercial or other purpose; and 
b) 
The procedures outlined above shall govern the defense professional’s use, 
maintenance, disclosure, and safekeeping of the evidence, except that the 
defense professional may maintain the discovery materials at their offices, 
but only under the same secure conditions provided above. 
8) 
Defense counsel shall promptly notify the government and the Court if any 
Confidential Discovery Materials are disclosed to anyone not designated by this Order or further 
order of the Court, either intentionally or unintentionally.  The defendant and any defense 
professional shall promptly notify defense counsel of any such disclosures. 
9) 
At the end of these proceedings, the defendants, the defense team, and the defense 
professionals shall return the Confidential Discovery Materials to the government or certify to the 
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government that the Confidential Discovery Materials have been destroyed. 
10) 
The defendant may challenge the government’s designation of any material as 
Confidential by first raising the issue with the government and, if the parties cannot agree, by 
raising it with the Court. 
11) 
Nothing in this Order will preclude any party from applying to the Court for further 
relief or for modification of any provision hereof.    
 
Dated:  _______________  
 
__________________________________________ 
HON. DAVID H. HENNESSY  
United States Magistrate Judge 
 
 
 Acknowledged by:  _____________________________________________ 
 
 
 
Individual receiving Confidential Discovery Materials 
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