Case 7:22-cr-00665-UA Document 10 Filed 12/12/22 Page 1 of 4
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DIS) RICT OF NEW YORK
`
`United States of America
`
`V.
`
`OLDAMO FRAZER,
`
`Defendant.
`
`
`FILED UNDER SEAL
`
`Protective Order
`
`22 Mag. 8233
`
`Uponthe application of the United States of America, with the consent ofthe undersigned
`
`counsel, the Court licreby finds and orders as follows:
`
`1. Disclosure Material. The Government will make disclosure to the defendant of
`
`documents, objects snd information, including electronically stored information (“ESI”), pursuant
`
`to Federal Rule of Criminal Procedure 16, 18 U.S.C. §3500, and the Government’s general
`
`obligation to produce exculpatory and impeachment material in criminal cases, all of which will
`
`be referred to hercin as “disclosure material.” The Government’s disclosure material may include
`
`material
`
`that (i) alivels the privacy and confidentiality of individuals;
`
`(11) would impede, if
`
`prematurely disclosed, the Government’s ongoing investigation of uncharged individuals; (iii)
`
`would risk prejudicial pretrial publicityif publicly disseminated; and (iv) that is not authorized to
`
`Case 7:22-cr-00665-UA Document 10 Filed 12/12/22 Page 1 of 4
`
`be disclosed to the public or disclosed beyond that which is necessary for the defense of this
`
`criminal casc.
`
`>. Sensitive Disclosure Material. Cerlain of the Government’s disclosure material,
`
`referred to herein as “sensitive disclosure material,” contains information that identifies, or could
`
`lead to the identificution of, witnesses who may be subject to intimidation or obstruction, and
`
`whoselives, persons, and property, as weil as the lives, persons and property of loved ones, will
`
`be subjectto risk of harm absentthe protective considerations set forth herein. The Government’s
`
`
`
`Case 7:22-cr-00665-UA Document 10 Filed 12/12/22 Page 2 of 4
`
`designation of material as sensitive disclosure material will be controlling absent contrary orderof
`
`the Coutt.
`
`NOW,THEREFORE, FOR GOO) CAUSE SHOWN,IT IS HEREBY ORDERED:
`
`1. Disclosure material shall not be disclosed by the defendant or defense counsel, including
`
`any successor couset (“the defensc”) other than as set forth herein, and shall be used by the
`
`defense solely for purposes of defending this action, The defense shall not post any disclosure
`
`material on anyInerncl site or network site to which persons otherthan the parties hereto have
`
`access, and shall i | disclose any disc!osure material to the media or any third party except as set
`
`forth below.
`
`2, Disclosure material that is not sensitive disclosure material may be disclosed by counsel
`
`to:
`
`(a} The cefendant;
`
`(b) Personnel for whose conduct counsel is responsible, /.e., personnelemployed by or
`
`retained by counse|. as neededfor purposes of defending this action;
`
`(b) Prospective witnesses lov purposes of defending this action.
`
`3. Sensitive disclosure material shall be disclosed only on an “attorneys eyes only” basis
`
`Case 7:22-cr-00665-UA Document 10 Filed 12/12/22 Page 2 of 4
`
`to counsc) Jor the ¢.lendant and employees of counsel for the defendant as needed for purposes of
`
`defending this actic-n.
`
`4, The Government may authorize,in writing, disclosure of disclosure material beyond that
`
`otherwise permitted by this Orderwithout further Order of this Court.
`
`
`
`Case 7:22-cr-00665-UA Document 10 Filed 12/12/22 Page 3 of 4
`
`5. this Order dees not prevent the disclosure of any disclosure material in any hearing or
`
`trial held in this action, or to any judes or magistrate judge, for purposes of this action. All filings
`
`should comply wil): the privacy protection provisions of Fed. R. Crim, P. 49.1.
`
`6. Except !
`
`¢ disclosure material that has been made part of the record of this case, the
`
`defense shall retur:
`
`to the Government or securely destroy or delete all disclosure material,
`
`including the seized LSE disclosure material, within 30 days of the expiration of the period for
`
`direct appeal from ny verdict in (he above-captioned case; the period of direct appeal from any
`
`order dismissing anyof the charges in tie above-captioned case; or the granting of any motion
`
`made on behalf of tie Governmentdismissing anycharges in the above-captioned case, whichever
`
`dateis later.
`
`7. ‘Vhis Order places no restriction on a defendant’s use or disclosure of ESIthatoriginally
`
`belongedto the defendant.
`
`[Cominued on next page|
`
`Case 7:22-cr-00665-UA Document 10 Filed 12/12/22 Page 3 of 4
`
`
`
`Case 7:22-cr-00665-UA Document 10 Filed 12/12/22 Page 4 of 4
`
`8. The previsions of this order shall not terminate at the conclusion of this criminal
`
`Retention of Jurisdiction
`
`prosecution and the Court will retain jurisdiction to enforce this Order following termination of
`
`the case.
`
`AGREED AND CONSENTED TO:
`
`DAMIAN WILLIAMS
`United States Aniorney
`
`Us uaUR ys
`
`Date:_11/8/22
`by:
`Qais Ghalary / Vinothy Ly
`Assistont Unite | States Attorneys
`
`Rone Vie
`
`Rachel Mattin, [s<.
`Counsel for O12 2AMO FRAZER
`
`Date:
`
`11/9/2022
`
`SO ORDERED:
`
`Dated: November * 718022
`White Plain . New York
`
`Case 7:22-cr-00665-UA Document 10 Filed 12/12/22 Page 4 of 4
`
`CeGp
`
`‘THE HONORABLE PAULE. DAVISON
`UNITED STATES MAGISTRATE JUDGE
`SOUTHERN DISTRICT OF NEW YORK
`
`
