UNI
TED STATES DISTRICT COURT  
FOR THE DISTRICT OF COLUMBIA 
UNI
TED STATES OF AMERICA   : 
: 
: v.     Crim No. 1:21- CR-00078-E GS 
:
 
JOHN EARLE SULLIVAN, : 
: 
Defendant.  : 
UNOPPOSED MOTION FOR PROTECTIVE ORDER 
T
he United States of America hereby respectfully moves the Court for  the entry of a 
protective order governing the production of discovery by the parties in the above -captioned case. 
The United States and counsel for Defendant have reached an agreement as to the proposed 
protective order. Therefore, the United States is authorized to represent to the Court that D efendant 
does not oppose this motion or the entry of the attached protective order. 
R
espectfully submitted,  
CHANNING D. PHILLIPS  
Acting United States Attorney  
D.C. Bar No. 415793
By: 
CANDICE C. WONG  
Assistant United States Attorney  
D.C. Bar No. 990903
555 Fourth Street, N.W., Room 4816Washington, D C 20530
Candice.wong@usdoj.gov(202) 252-7849
Case 1:21-cr-00078-EGS   Document 20   Filed 03/26/21   Page 1 of 1