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Case 1:20-cr-00330-AJN Document 61 Filed 07/28/20 Page 8 of 12

e) Shall be reviewed by the Defendant solely in
the presence of Defense Counsel or when provided access to
Discovery materials in electronic format by BOP officials;

f) May be disclosed only by Defense Counsel and
only to Designated Persons;

g) May be shown to, either in person, by
videoconference, or via a read-only document review platform,
but not disseminated to or provided copies of to, Potential
Defense Witnesses, to the extent deemed necessary by Defense
Counsel, for trial preparation, and after such individual(s)
have read and signed this Order acknowledging that such
individual(s) are bound by this Order.

11. Copies of Discovery or other materials produced
by the Government in this action bearing “highly confidential”
stamps or otherwise specifically designated as “highly
confidential,” and/or electronic Discovery materials designated
as “highly confidential” by the Government, including such
materials marked as “highly confidential” either on the
documents or materials themselves, or designated as “highly
confidential” in an index, folder title, or document title, are
deemed “Highly Confidential Information.” To the extent any
Highly Confidential Information is physically produced to the
Defendant and Defense Counsel, rather than being made available
to the Defendant and Defense Counsel for on-site review, the

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App.070
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