Protective Order Governing Discovery — No. 1:20-cr-00293 (Dkt. 152, N.D. Ill.)

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Judge Robert M. Dow, Jr. entered this protective order on the government's agreed motion in No. 20 CR 293 in the Northern District of Illinois, filed October 20, 2022. It covers materials the government provides under the court's order granting in part Rahul Shah's motion for a forensic examination (Dkt. No. 145). Defense counsel may use them only for this case and may not disclose them to Shah or to anyone other than people assisting with the forensic examination, or send them outside the United States without the court's permission.

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Case: 1:20-cr-00293 Document #: 152 Filed: 10/20/22 Page 1 of 3 PagelD #:817

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION
UNITED STATES OF AMERICA
No. 20 CR 293
V.
Judge Robert M. Dow, Jr.
RAHUL 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, records, and information provided by the United
States in response to this Court’s order granting in part defendant’s motion for a
forensic examination (Dkt. No. 145), or in response any subsequent Order of this
Court requiring disclosure of additional information relating to the defendant’s
motion for a forensic examination (collectively, “the materials”) are subject to this
protective order and may be used by 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’s counsel shall not disclose the materials or their contents
directly or indirectly to defendant or any person or entity other than persons
employed to assist in the defense with the forensic examination (collectively,

“authorized persons”). The materials and their contents shall not be disclosed either

Case: 1:20-cr-00293 Document #: 152 Filed: 10/20/22 Page 2 of 3 PagelD #:818

directly or indirectly to any person or entity outside of the United States without prior
authorization from the Court.

3. 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’s counsel and authorized persons. Such copies
and reproductions shall be treated in the same manner as the original materials.

4, 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 and require the
authorized person to sign a statement acknowledging that the authorized person has
received a copy of and reviewed this Order, and has agreed to be bound by its terms
and conditions subject to sanctioning by the Court for any violations of this Order.
Defense counsel shall maintain a copy of the signed statement of each authorized
person for a period of twelve months after the conclusion of all stages of this case, and
shall provide copies of the signed statement of each authorized person to the

government upon request.

Case: 1:20-cr-00293 Document #: 152 Filed: 10/20/22 Page 3 of 3 PagelD #:819

6. Upon conclusion of all stages of this case, all of the materials and all
copies made thereof shall be returned to the United States Attorney’s Office for the
Northern District of Illinois.

Bs 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. 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;

Vea am

ROBERT M. DOW, IBZ
District Court J a

United States District Court
Northern District of Illinois

Date: Defake av, 2072-

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