Document 13-1

Case 1:19-cr-00490-RMB Document 13-1 Filed 07/15/19 Page 1 of 1 COMMONWEALTH OF MASSACHUSETTS SUFFOLK, SS. BE IT REMEMBERED, that at the Supreme Judicial Court holden at Boston within and for said County of Suffolk, on the twenty-fourth day of April A.D. 1972 , said Court being the highest Court of Record in said Commonwealth: Martin G. Weinberg being found duly qualified in that behalf, and having taken and subscribed the oaths required by law, was admitted to practice as an Attorney, and, by virtue thereof, as a Counsellor at Law, in any of the Courts of the said Commonwealth: that said Attorney is at present a member of the Bar, and is in good standing according to the records of this Court*. In testimony whereof, I have hereunto set my hand and affixed the seal of said Court, this eleventh day of July in the year of our Lord two thousand and nineteen. MAURA S. DOYLE, Clerk * Records of private discipline, if any, such as a private reprimand imposed by the Board of Bar Overseers or by any court are not covered by this certification. X3116 DOJ-OGR-0000363 --- PAGE BREAK --- Case 1:19-cr-00830-AT Document 13-1 Filed 12/16/19 Page 2 of 5 parties, could, among other things, impede ongoing investigations and implicate the privacy and confidentiality interests of third parties; WHEREAS, the Government has demonstrated good cause for the relief set forth herein; WHEREAS, TOVA NOEL and MICHAEL THOMAS, the defendants, by and through their respective counsel of record, consent to the entry of this Order; NOW, THEREFORE, IT IS HEREBY ORDERED, pursuant to Federal Rule of Criminal Procedure 16(d): 1. Discovery materials designated as "Protected Materials" by the Government may be used by the defendants, their respective counsel of record, and their respective counsel of record's agents (collectively, the "Defense") only for purposes of defending the charges, in connection with any sentencing, and pursuing any appeals, in relation to this criminal action. 2. The Protected Materials and the information contained or disclosed therein: a. Shall not be disclosed in any form by the Defense to any third party except as set forth in paragraphs 2(b), 3, and 4 below; b. May be disclosed to third parties only by the defendants' respective counsel of record and only to the following persons (collectively, "Designated Persons"): DOJ-OGR-00021955 --- PAGE BREAK --- Case 1:19-cr-00830-AT Document 13-1 Filed 12/16/19 Page 3 of 5 i. investigative, secretarial, clerical, paralegal and student personnel employed full-time or part-time by the defendants' respective counsel of record and who are actually participating in the legal defense of this action; ii. independent expert witnesses, jury consultants, document hosting personnel, or investigators retained by the defendants in connection with this action; iii. such other persons as hereafter may be authorized by the Court upon a motion by the defendants; and iv. Shall be destroyed or returned to the Government following the conclusion of this case, including after any appeals. 3. The Defense may show (but not otherwise provide) the Protected Materials to fact witnesses ("Fact Witnesses") interviewed by the defendants' respective counsel of record or by the Designated Persons in the course of investigating this action. 4. The Defense shall provide a copy of this Order to Designated Persons to whom materials subject to the protections of this Order are disclosed pursuant to paragraph 2(b), or Fact Witnesses to whom materials subject to the protections of this Order are shown pursuant to paragraph (3). Designated Persons and Fact Witnesses shall be subject to the terms of this Order. 5. With respect to any discovery material designated as Protected Materials that the Defense intends to file publicly or --- PAGE BREAK --- to specifically describe in a public filing, the defendant making the filing must either (i) file the discovery material under seal, or (ii) provide reasonable notice to the Government to permit the parties to confer on the proper treatment of the discovery material. If the parties are unable to reach agreement as to whether redactions to the public filings are warranted, or to the extent of such redactions, the parties will seek Court resolution before the document is publicly filed or specifically described in a public filing. --- PAGE BREAK --- Case 1:19-cr-00830-AT Document 13-1 Filed 12/16/19 Page 5 of 5 6. Any disputes regarding the designation of discovery material as Protected Materials, or any other dispute concerning this Order, which cannot be resolved among the parties, will be brought to the Court for a ruling before any public disclosure not permitted by this Order is made. Dated: New York, New York December __, 2019 SO ORDERED: THE HONORABLE ANALISA TORRES UNITED STATES DISTRICT JUDGE DOJ-OGR-00021958