SEC Charges Eleven in Stock Manipulation Ring

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09/11/2009 20 Letter to Honorable Joseph J. Farnan, Jr. from AUSA Shannon T. Hanson regarding proposed Stipulated Protective Order. (Attachments: # 1 Text of Proposed Order Proposed Stipulated Protective Order)(Hanson, Shannon) (Entered: 09/11/2009)
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Doc 20 OCR extract

Re: United States v. Gerard D'Amaro
Crim. Action No. 09-54-JJF

Dear Judge Farnan:

The parties in the above-captioned case have agreed upon a proposed Stipulated Protective Order to govern the discovery process. A copy of the proposed Order is attached hereto, which has been executed by counsel for the government and the defendant.

Pursuant to Fed. R. Crim. P. 16(d)(1), we respectfully ask that the Court enter the proposed Protective Order. As set forth therein, it is necessary in this case because, among other things, the discovery materials contain a significant amount of third-party financial and identity information.

We remain available to address any questions that the Court may have.

Respectfully submitted,
DAVID C. WEISS United States Attorney

BY:
Keith M. Rosen
Shannon T. Hanson
Assistant United States Attorneys