EXHIBIT A

Case 1:14-cr-10221-WGY Document 36-1 Filed 08/27/14 Page 1 of 5

UNITED STATES DISTRICT COURT
DISTRICT MASSACHUSETTS

_____________________________
)
UNITED STATES OF AMERICA ) Criminal No. 14-CR-10221-WGY
)
v. )
)
MICHAEL AFFA, )
ANDREW AFFA, )
MITCHELL BROWN, )
CHRISTOPHER PUTNAM, and )
CHRISTOPHER NIX, )
a/k/a GABE NIX, )
)
Defendants. )
_____________________________ )


[PROPOSED] PROTECTIVE ORDER

A motion having been made by the government pursuant to Rule 16 of the Federal Rules
of Criminal Procedure and Local Rule 116 for a protective order which prohibits the disclosure
of discovery materials (including documents and recordings), and information contained therein,
by defense counsel except for the purpose of the legal defense in the case captioned above, and
which restricts the disclosure and use of materials by the defendants, it is hereby ORDERED, as
follows:
1) The discovery materials produced by the government in this case (the Protected
Materials) may be used by the defendants, defense counsel of record and any employees or agents
of defendants counsel (members of the office of defense counsel who are directly engaged in
assisting in the legal defense of this case, and other persons retained by defense counsel for the
purpose of assisting in the legal defense of this case) solely in the defense of this case and for no
other purpose and in connection with no other proceeding.
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2) Defense counsel of record will not disclose any Protected Materials, directly or
indirectly, to any other person except those assisting the defense, persons who are interviewed as
potential witnesses, potential experts, or other authorized persons, during the course of the
investigation and defense of this case.
3) Defense counsel of record may disclose Protected Materials to potential witnesses
only for the purpose of the legal defense in this matter, provided that defense counsel of record
have made a good faith determination that such disclosure is necessary to the proper preparation
of the legal defense in this case. Copies of such materials, however, shall only be shown or
played, and shall not be given, to such witnesses.
4) Prior to disclosing any materials, or information contained therein, to any
potential witness as set forth in Paragraphs 2 and 3 of this Order, defense counsel of record shall
fully explain the terms of this Order and obtain from each potential witness to whom such
disclosure is made, an acknowledgment of the terms of this Order and their agreement to comply
with its terms.
5) Defense counsel of record may disclose Protected Materials to the defendant
whom counsel represents for the purpose of the legal defense in this case so long as the
defendant: (a) has signed the attached Agreement To Be Bound By Order; (b) does not make any
copies of the materials produced to him by defense counsel; and (c) returns all materials, or
documents reflecting the information contained in the materials, to defense counsel of record at
the conclusion of the case.
6) Neither the defendant nor any other person receiving from defense counsel of
record or the agents of defense counsel the Protected Materials, or the information contained
therein, disclosed to defense counsel by the government in this case is permitted to further
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disseminate or further disclose such materials or information for any purpose at any time. This
prohibition shall not limit or bar any person from testifying under oath as to the Protected
Materials.
7) Nothing contained in the Protective Order will preclude any party from applying to
the Court for further relief or for modification of any provision hereof.

______________________________________
WILLIAM G. YOUNG
UNITED STATES DISTRICT JUDGE

Dated: _____________

Case 1:14-cr-10221-WGY Document 36-1 Filed 08/27/14 Page 4 of 5


AGREEMENT TO BE BOUND BY ORDER

I hereby acknowledge that I have read the contents of the above protective order entered
in United States v. Michael Affa et al., 14-CR-10221-WGY, and have had the terms explained to
me. I agree that the order applies to me, that I am bound by its terms, and that I shall comply
with its terms.


________________________
NAME:


________________________
DATE


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