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Case 1:19-cr-00830-AT Document16 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, their respectiv counsel of record, and their respective counsel of record’s agents (collectively, the “Defense”) only for purposes of defending the charges, in connection with any sentencing, and pursuing any appeals, in relation to this criminal action. 2. The Protected Materials and the information contained or disclosed therein: a. Shall not be disclosed in any form by the Defense to any third party except as set forth in paragraphs 2(b), 3, and 4 below; b. May be disclosed to third parties only by the defendants’ respective counsel of record and only to the following M“ persons (collectively, “Designated Persons”): DOJ-OGR-00021973