Case 1:19-cr-00830-AT Document 13-1 Filed 12/16/19 Page1lof5 x PROTECTIVE ORDER 19 Cr. 830 (AT) x UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA -v.- TOVA NOEL and MICHAEL THOMAS, Defendants. On the motion of States Attorney for the Southern the United States of America, District of New York, Geof by the United frey S. Berman, by Assistant United States Attorneys Rebekah Donaleski, Nicolas Roos, and Jessica Lonergan; and with the consent of TOVA NOEL and MICHAEL THOMAS, the defendants, by and through their respective counsel of record: WHEREAS, TOVA NOEL and MICHAEL THOMAS, the defendants, have certain rights under the United States Constitution, federal statutes, and the Federal Rules of Criminal Procedure, to pretrial discovery; WHEREAS, the Government recognizes its obligation to provide such discovery materials to the defendants, need to protect the con fFidential ity of KAS, the con WHER to the dei fendants contain mat fFidentiality interests of the discovery terials that, others; i consistent with the ongoing investigations and that the Government intends to provide f disseminated to third DOJ-OGR-00021954