Trump Protective Order

Case 9:23-cr-80101-AMC Document 27 Entered on FLSD Docket 06/19/2023 Page 1 of 5
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
CASE NO. 23-80101-CR-CANNON-REINHART
UNITED STATES OF AMERICA
v.
DONALD J. TRUMP and

WALTINE NAUTA,
Defendants.
/
RULE 16 PROTECTIVE ORDER
Upon consideration of the Government’s motion for a protective order pursuant to Rule
16(d)(1) of the Federal Rules of Criminal Procedure, and after consideration of the motion and the
entirety of the record, it is hereby ORDERED as follows:
1. Definition of Discovery Materials. All non-classified discovery produced by the
United States to the Defendants in preparation for, or in connection with, any stage of this case
(collectively, “the Discovery Materials”) are subject to this protective order (“the Order”) and may
be used by the Defendants and Defense Counsel (defined as counsel of record in this case) solely in
connection with the defense of this case, and for no other purpose, and in connection with no other
proceeding, without further order of this Court.
2. Storage of Discovery Materials. Discovery Materials must be maintained in the
custody and control of Defense Counsel. Defense counsel shall store the Discovery Materials
securely with labels that make it clear that the materials are subject to the Order. Electronic materials
or copies of the Discovery Materials shall be stored in the same manner.
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3. Disclosure of Discovery Materials. Defendants and Defense Counsel shall not
disclose the Discovery Materials or their contents directly or indirectly to any person or entity other
than persons employed to assist in the defense, persons who are interviewed as potential witnesses,
counsel for potential witnesses, and other persons to whom the Court may authorize disclosure
(collectively, “Authorized Persons”). Before providing materials to an Authorized Person, Defense
Counsel must provide the Authorized Person with a copy of this Order, and Defense Counsel shall
obtain from each person to whom disclosure will be made a signed Protected Discovery Material
Agreement (“Agreement”) available as Attachment A to the Order in which the recipient (1)
acknowledges the restrictions set forth in this Order, and (2) agrees that he/she will not further
disclose or disseminate the Discovery Materials. Defense Counsel shall keep a copy of each signed
Agreement to identify the individuals who received the Discovery Materials and the date on which
such information was first disclosed. No disclosure is permitted to any individual or entity that has
not signed such Agreement, except by further order of the Court. Potential witnesses and counsel
for potential witnesses may be shown copies of the Discovery Materials as necessary to prepare the
defense, but they may not retain copies without prior permission of the Court.
4. Copies of Discovery Materials. Defendants, Defense Counsel, and Authorized
Persons shall not copy or reproduce the Discovery Materials except as necessary to prepare for the
defense. Copies and reproductions shall be treated in the same manner as the original Discovery
Materials. The Defendants, Defense counsel, and Authorized Persons shall not disclose any notes
or records of any kind that they make in relation to the contents of the materials, other than to
Authorized Persons, and all such notes or records are to be treated in the same manner as the original
Discovery Materials. The Discovery Materials shall not be copied or reproduced by Defendants or
anyone acting on the Defendants’ behalf, except Defense Counsel or agents of Defense counsel.
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5. Defendants’ Review of Discovery Materials. Defendants shall only have access to
Discovery Materials under the direct supervision of Defense Counsel or a member of Defense
Counsel’s staff. Defendants shall not retain copies of Discovery Material. Defendants may take
notes regarding Discovery Materials, but such notes shall be stored securely by Defense Counsel or
a member of Defense Counsel’s staff in the same manner as the Discovery Materials.
6. No Disclosure to the Public. The Discovery Materials, along with any information
derived therefrom, shall not be disclosed to the public or the news media, or disseminated on any
news or social media platform, without prior notice to and consent of the United States or approval
of the Court.
7. Use of Discovery Material in Court. The procedures for use of Discovery Material
during any hearing or trial of this matter shall be determined by the parties and the Court in advance
of the hearing or trial. Defendants shall not disclose Discovery Material in any public filing or in
open court without notice to, and agreement from, the United States, or prior approval from the
Court.
8. Return of Discovery Materials. Within 90 days of the conclusion of all stages of
this case, including all related appeals, all Discovery Materials and all copies thereof shall be
destroyed by Defense Counsel or returned to the United States, unless otherwise ordered by the
Court. The Court may require a certification as to the disposition of any such materials.
9. Violations. A knowing violation of this Order by Defendants, Defense Counsel, and
Authorized Persons may result in contempt of court or other civil or criminal sanctions.
10. Modification of this Order. This Order may be modified by the agreement of the
parties with permission of the Court or by further Order of the Court. Nothing in this Order shall
prevent any party from objecting to discovery that it believes to otherwise be improper.
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11. No Ruling on Discoverability or Admissibility. This Order does not constitute a
ruling on the question of whether any particular material is properly discoverable or admissible and
does not constitute any ruling on any potential objection to the discovery of any material.
12. The restrictions set forth in this Order do not apply to documents that are or become
part of the public court record, nor do the restrictions in this Order limit Defense Counsel in the use
of the materials in judicial proceedings in this case, except as described above.
DONE AND ORDERED in Chambers at West Palm Beach, Florida, this 19th day of June, 2023.
BRUCE E. REINHART
UNITED STATES MAGISTRATE JUDGE
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Attachment A to Protective Order
I _________________________ have read the Rule 16 Protective Order in United States
v. Donald J. Trump and Waltine Nauta. I have carefully reviewed each provision. I fully
understand the Protective Order, and I voluntarily agree to abide by its restrictions. I am an
Authorized Person under the Protective Order, and I will not further disclose or disseminate the
Discovery Materials.
________________ ________________________________________________
Date Signature

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Case 9:23-cr-80101-AMC Document 27 Entered on FLSD Docket 06/19/2023 Page 1 of 5

UNITED STATES DISTRICT COURT

CASE NO. 23-80101-CR-CANNON-REINHART

UNITED STATES OF AMERICA

DONALD J. TRUMP and

RULE 16 PROTECTIVE ORDER

entirety of the record, it is hereby ORDERED as follows:

1. Definition of Discovery Materials. All non-classified discovery produced by the

proceeding, without further order of this Court.

2. Storage of Discovery Materials. Discovery Materials must be maintained in the

or copies of the Discovery Materials shall be stored in the same manner.

3. Disclosure of Discovery Materials. Defendants and Defense Counsel shall not

(collectively, “Authorized Persons”). Before providing materials to an Authorized Person, Defense

4. Copies of Discovery Materials. Defendants, Defense Counsel, and Authorized

5. Defendants’ Review of Discovery Materials. Defendants shall only have access to

8. Return of Discovery Materials. Within 90 days of the conclusion of all stages of

9. Violations. A knowing violation of this Order by Defendants, Defense Counsel, and

11. No Ruling on Discoverability or Admissibility. This Order does not constitute a

of the materials in judicial proceedings in this case, except as described above.

Attachment A to Protective Order

I _________________________ have read the Rule 16 Protective Order in United States

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