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House Oversight — DOJ production

DOJ-OGR-00021954

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pdf
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013-01.pdf
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House Oversight (DOJ)
Pages
5
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Case 1:19-cr-00830-AT Document13-1 Filed 12/16/19 Page1of5   UNITED STATES DISTRICT COURT SOUTHERN DISTR T                   - 5 5 FF X         a5 UNIT   iD STATES OF AMERICA ig PROTECTIVE ORDER       =V.5 3 19 Cr. 830 (AT) TOVA NOEL and MICHAEL THOMAS,   Defendants. 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 DOJ-OGR-00021954 

Case 1:19-cr-00830-AT Document13-1 Filed 12/16/19 Page2of5 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): Ls 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 c

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