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Case 1:19-cr-00830-AT Document 13-1 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, T S 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, counsel of record, and their respectiv their respectiv for purposes of sentencing, counsel of record’s agents de fending the and pursuing any action. (collectively, the “Defense”) only charges, in connection with any appeals, in relation to this criminal 2. The Protected Materials and the information contained or disclosed therein: to any third party except as set a. Shall not be disclosed forth in paragraphs 2(b), to third parties record and only to the Defense in any form by the 3, and only by the following 4 below; b. May be disclosed defendants’ respective counsel of persons (collectively, “Designated Persons”): DOJ-OGR-00021955