PROTECTIVE ORDER

LAURA TAYLOR SWAIN, District Judge.

Upon the application of the United States of America, Geoffrey S. Berman, United States Attorney for the Southern District of New York, by and through Ryan Finkel and Mollie Bracewell, Assistant United States Attorneys, of counsel, for an order precluding the dissemination of material produced pursuant to Fed R. Crim. P. 16 ("Rule 16 Material") and providing additional protections to a designated subset of Rule 16 Material which has been classified as "Highly Confidential,"1 and based on the Court's independent review,

IT IS HEREBY ORDERED that

(1) defense counsel must destroy or return to the Government all Rule 16 Material (and any copies thereof) at the conclusion of this matter or when any appeal has become final;

(2) the defense and the defendant are precluded from disseminating any of the Highly Confidential Rule 16 Material to anyone beyond the defendant, defense counsel, and any paralegal or staff employed by the defense; and

(3) the defendant is precluded from taking or keeping any copies, or derivative notes, of the Highly Confidential Rule 16 Material with them including into any jail facility; except that the defendant may review copies of the Highly Confidential Rule 16 Material in the possession of defense counsel or any paralegal or staff employed by the defense, when in the presence of defense counsel or any paralegal or staff employed by the defense.

IT IS FURTHER ORDERED that the defendant, defense counsel, and any paralegal or staff employed by the defense are precluded from publicly disclosing or disseminating the identity of any witnesses or victims identified in the Rule 16 Material.