[PROPOSED] ORDER

VINCE CHHABRIA, District Judge.

Upon motion of the government and for good cause shown, IT IS HEREBY ORDERED THAT the government, pursuant to Title 26, United States Code, Section 6103(h)(4)(D), may disclose to Defendant Kamran Azizi and Defendant Hedyeh Shoar, and their attorneys, the "returns" and "return information" gathered during the course of the investigation of Defendants in order to satisfy its obligations pursuant to Rule 16 of the Federal Rules of Criminal Procedure, 18 U.S.C. § 3500, and Brady v. Maryland and its progeny. For purposes of this Order, "return" and "return information" shall be defined as set forth in Section 6103.

IT IS FURTHER ORDERED that:

1. Defendants, their attorneys, and all other individuals or entities assisting Defendants who receive materials in connection with this case are prohibited from directly or indirectly providing access to, or otherwise disclosing the contents of, these materials to anyone not working on the defense of this criminal case, or otherwise making use of the materials in a manner unrelated to the defense of this criminal case. Authorized use of materials related to the defense of this criminal case shall include showing and discussing such materials with government and defense witnesses.

2. Defendants, their attorneys, and all other individuals or entities who receive materials in connection with this case, shall maintain all materials in a manner consistent with the terms of this Order. Materials produced to the defense after entry of this Order shall be stored in a secure manner in boxes, files, or folders marked "UNDER PROTECTIVE ORDER — DO NOT DISCLOSE." Electronic materials produced to the defense and printouts obtained from electronic materials shall be handled in the same manner.

3. Defendants and their attorneys are required to give a copy of this Order to all individuals or entities engaged or consulted by the defense in preparation for trial in this case. A violation of this Order by Defendants, their attorneys, or others may result in contempt of court proceedings or other civil or criminal sanctions.

4. Within 90 days of the conclusion of this case, including all related appeals, all documents produced pursuant to this Order, and all copies thereof (other than exhibits of the Court), shall be returned to the United States Attorney's Office. Alternatively, Defendants or their attorneys may inform the United States Attorney's Office in writing that all such copies have been destroyed.

5. The provisions of this Order shall not terminate at the conclusion of this criminal prosecution.

IT IS SO ORDERED.