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Case 1:19-cr-00830-AT Document13-1 Filed 12/16/19 Page3of5 1. investigative, secretarial, clerical, paralegal and student personnel employed full-time or part-time by the defendants’ respective counsel of record and who are actually participating in the legal defense of this action; ii. independent expert witnesses, Jury consultants, document hosting personnel, or investigators retained by the defendants in connection with this action; iii. such other persons as hereafter may be authorized by the Court upon a motion by the defendants; and iv. Shall be destroyed or returned to the Government following the conclusion of this case, including after any appeals. 3. The Defense may show (but not otherwise provide) the Protected Materials to fact witnesses (“Fact Witnesses”) interviewed by the defendants’ respective counsel of record or by the Designated Persons in the course of investigating this action. 4, The Defense shall provide a copy of this Order to Designated Persons to whom materials subject to the protections of this Order are disclosed pursuant to paragraph 2(b), or Fact Witnesses to whom materials subject to the protections of this Order are shown pursuant to paragraph (3). Designated Persons and Fact Witnesses shall be subject to the terms of this Order. oF With respect to any discovery material designated as Protected Materials that the Defense intends to file publicly or DOJ-OGR-00021956