Limitations Concerning Sharing of Discovery

(a) Distribution. Parties and their counsel shall not distribute materials received in discovery, or copies of such materials, except to the following: (1) members of the litigation team (e.g., the party, counsel, paralegals, investigators, and support staff); (2) experts or consultants retained or appointed to testify or assist in the preparation of the litigation, including their support staff; (3) (4) (5) the United States Marshals Service; the United States Probation Office; and the Court. (b) Prohibition on Further Distribution. Recipients listed in subsection (a) shall not further distribute discovery materials to anyone not listed in subsection (a).

Counsel shall inform recipients of this requirement. (c) Permitted Review. Notwithstanding the above, counsel for a party may review information received in discovery with individuals who are not listed in subsection (a), but that review shall be conducted in the presence of that attorney and the individual shall not retain possession of the information following the review. (d) Requests for Modification.

A party may file a motion seeking modifications to the limitations contained herein. Such a motion may be filed ex parte. 28