Protective Order Governing Discovery — No. 1:25-cr-00508 (Dkt. 23, N.D. Ill.)

Summary

A Protective Order Governing Discovery, Document 23, dated October 22, 2025 in United States v. Jonathan Scott, No. 25 CR 508, before Judge Sara L. Ellis in the U.S. District Court for the Northern District of Illinois, Eastern Division. Entered on the government's agreed motion under Fed. R. Crim. P. 16(d) and 18 U.S.C. § 3771(a)(1) and (8), it covers materials marked SENSITIVE that contain personal identifying information of persons other than the defendant and state grand jury information. Defense counsel must keep a record of each person to whom the materials are disclosed, to be given to the Court on request but not to the government unless the Court orders. The defendant may not disclose the materials without a court order, and marked information goes under seal. Mistaken productions must be returned within five days.

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    Case: 1:25-cr-00508 Document #: 23 Filed: 10/22/25 Page 1 of 5 PageID #:51




                      UNITED STATES DISTRICT COURT
                      NORTHERN DISTRICT OF ILLINOIS
                           EASTERN DIVISION

UNITED STATES OF AMERICA
                                              No. 25 CR 508
             v.
                                              Judge Sara L. Ellis
JONATHAN SCOTT

              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.    The     Sensitive    Materials:     Certain   materials,   marked    as

“SENSITIVE,” provided by the United States in preparation for, or in connection

with, any stage of the proceedings in this case (collectively, “the Sensitive

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. These sensitive materials

contain personal identifying information of one or more persons other than the

defendant and state grand jury information. These materials shall be plainly marked

as SENSITIVE by the government prior to disclosure.

      2.    Limits on Disclosure: Defendant’s counsel shall not disclose the

Sensitive Materials or their contents directly or indirectly to any person or entity

other than (a) defendant, (b) persons employed to assist in the defense, (c) persons

who are interviewed as potential witnesses and counsel for potential witnesses, and
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(d) other persons to whom the Court may authorize disclosure (hereinafter,

individuals other than defendant referred to, collectively, as “authorized persons”).

Defendant’s counsel shall not copy or reproduce the Sensitive Materials except in

order to provide copies of the materials for use in connection with this case, within

the limits of this Protective Order. Such copies and reproductions shall be treated in

the same manner as the original Sensitive Materials. Potential witnesses and their

counsel may be shown copies of the Sensitive Materials as necessary to prepare the

defense, but may not retain copies without prior permission of the Court.

      3.      Defense Counsel’s Responsibility to Advise Persons of this

Order: Before the Sensitive Materials or their contents are provided directly or

indirectly to defendant or an authorized person, defense counsel must advise the

defendant or authorized person of this Order and provide that person with a copy of

this Order.

      4.      Records   Regarding      Individuals    To   Whom      the    Sensitive

Materials – or the Contents of the Sensitive Materials – Are Disclosed:

Defense counsel shall maintain a record of any person to whom the sensitive

materials – or their contents – were disclosed. Defense counsel shall maintain a

record demonstrating that these individuals have been advised of the terms of this

protective order, provided a copy of this protective order, and have signed at the

bottom of the copy of the protective order to document that the individuals have been

advised of the protective order. Defense counsel will not disclose such records to the




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government, unless the Court so orders, but will disclose such records to the Court

upon request.

      5.     Defendant May Not Disclose the Sensitive Materials. Defendant

is not authorized to disclose the Sensitive Materials or their contents to any person

without applying to this Court for an order authorizing him/her to make such

disclosures. This paragraph does not apply to defense counsel, who may disclose the

sensitive materials as otherwise discussed in this order.

      6.     Limits on Filing Sensitive Materials: Absent prior permission from

the Court, copies, in whole or in part, of information marked as sensitive shall not be

included in any public filing with the Court, and instead shall be submitted under

seal (except if the defendant chooses to include in a public document sensitive

information relating solely and directly to the defendant).

      7.     Limits on Publicly Identifying Certain Third Parties Identified

in the Sensitive Materials: The Sensitive Materials will identify victims,

witnesses, and/or individuals who provided information to law enforcement. The

names (full, partial, or initials) of such individuals, other than law enforcement

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

submitted under seal.

      8.     Copies to Be Treated as Originals: 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,




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defendant’s counsel, and authorized persons. Such copies and reproductions shall be

treated in the same manner as the original sensitive materials.

      9.     Notes to Be Treated as Originals: 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

sensitive materials.

      10.    Disposal of the Sensitive Materials: Upon conclusion of all stages of

this case, all of the Sensitive Materials and all copies made thereof shall be disposed

of in one of three ways, unless otherwise ordered by the Court. The Sensitive

Materials may be (1) destroyed; (2) returned to the United States; or (3) retained in

defense counsel's case file. Defendant may not retain copies of the Sensitive

Materials. 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.

      11.    Mistaken Production: 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



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certify in writing that all copies of the specified material have been deleted from any

location in which the material was stored.

      12.    Exceptions: 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.

      13.    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:



                                         Sara L. Ellis
                                         Judge
                                         United States District Court
                                         Northern District of Illinois

Date: October 22, 2025




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