Case 1:19-cr-00830-AT Document16- Filed larry P ELECTRONICALLY FILED DOC #: DATE FILED: UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK 12/16/2019 ee ek x UNITED STATES OF AMERICA & PROTECTIVE ORDER -V.- = 19 Cr. 830 (AT) TOVA NOEL and F MICHAEL THOMAS, Defendants. , ee ” On the motion of the United States of America, by the United States Attorney for the Southern District of New York, Geoffrey 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, consistent with the need to protect the confidentiality of ongoing investigations and the confidentiality interests of others; WHEREAS, the discovery that the Government intends to provide to the defendants contain materials that, if disseminated to third DOJ-OGR-00021972