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Case 1:19-cr-00830-AT Document 13-1 Filed 12/16/19 Page 1 of 5
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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UNITED STATES OF AMERICA : PROTECTIVE ORDER
-v.- : 19 Cr. 830 (AT)
TOVA NOEL and :
MICHAEL THOMAS,
:
Defendants.
:
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On the motion of the United States of America, by the United
States Attorney for the Southern District of New York, Geoffrey S.
Berman, by Assistant United States Attorneys Rebekah Donaleski,
Nicolas Roos, and Jessica Lonergan; and with the consent of TOVA
NOEL and MICHAEL THOMAS, the defendants, by and through their
respective counsel of record:
WHEREAS, TOVA NOEL and MICHAEL THOMAS, the defendants, have
certain rights under the United States Constitution, federal
statutes, and the Federal Rules of Criminal Procedure, to pretrial
discovery;
WHEREAS, the Government recognizes its obligation to provide
such discovery materials to the defendants, consistent with the
need to protect the confidentiality of ongoing investigations and
the confidentiality interests of others;
WHEREAS, the discovery that the Government intends to provide
to the defendants contain materials that, if disseminated to third
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 F
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