Case 1:16-cr-10305-NMG Document 42-1 Filed 11/21/16 Page 1 of 4

UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA

v.
Crim. No. 16-cr-10305-NMG
MARTIN GOTTESFELD,

Defendant.

PROTECTIVE ORDER

Upon consideration of the governments Assented-To Motion for a Protective Order, it is

hereby ORDERED that:

1) The discovery materials produced by the government in this case may be used by the

defendant, defendants counsel, any employees or agents of defendants counsel, and any experts

or investigators retained by defense counsel (collectively, the defense) solely in order to

litigate this case (including investigation, pretrial motions, trial preparation, trial, and appeal) and

for no other purpose and in connection with no other proceeding.

2) Each person receiving access to the discovery materials, including members of the

defense, shall, after reviewing this Order, sign and date a copy of the attached Agreement To Be

Bound By Order, and defendants counsel shall file such an endorsed copy with the Court.

Such filings may be made ex parte and under seal. No one may review the discovery materials

unless he or she first signs a copy of this Order.

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3) Except as set forth below, the defense shall not show or make the discovery materials

available by any means (electronic, physical or otherwise) to any person who is not a member of

the defense, absent further order of this Court.

4) Once a potential witness who is not a member of the defense has signed a copy of the

attached Agreement To Be Bound By Order, the defense may show the potential witness the

discovery materials necessary to prepare the potential witness, but may not allow the potential

witness to retain discovery materials or copies thereof.

5) Defendant may view discovery materials only in the presence of another member of

the defense. Defendant may not retain discovery materials or copies thereof. Notes taken by the

defendant containing information from discovery materials shall be retained by defense counsel.

6) Defense counsel shall promptly notify the government and this Court if any discovery

materials are: (a) used in a manner inconsistent with this order, or (b) disclosed intentionally or

unintentionally to anyone not designated by this Order or further order of the Court. Each

member of the defense and any potential witnesses provided access to discovery materials shall

promptly notify defense counsel of any such disclosures.

7) At the conclusion of these proceedings, including any potential appeals, the defense

shall destroy all copies of discovery materials received and made by it. Defense counsel may

keep one copy of all discovery materials for such additional time as they deem necessary to

ensure their ability to satisfy all professional obligations to Defendant in this matter.

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Nothing contained in the Protective Order will preclude any party from applying to the

Court for further relief or for modification of any provision hereof.

__________________________________
MARIANNE B. BOWLER
UNITED STATES MAGISTRATE JUDGE

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AGREEMENT TO BE BOUND BY ORDER

I hereby acknowledge that I have read the contents of the above protective order

entered in United States v. Martin Gottesfeld, 16-cr-10305-NMG, and have had the

terms explained to me. I agree that the order applies to me, that I am bound by its terms, and that

I shall comply with its terms.

________________________
NAME

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DATE