SEC Charges Eleven in Stock Manipulation Ring

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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.

09/21/2009 16 Letter to Honorable Joseph J. Farnan, Jr. from AUSA Shannon T. Hanson regarding proposed Stipulated Protective Order.
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Doc 16 OCR extract

September 21, 2009

Via CM/ECF

Honorable Joseph J. Farnan, Jr.
United States District Court for the District of Delaware
J. Caleb Boggs Federal Building
844 King Street
Wilmington, DE 19801

Re: United States v. Matthew W. Brown
Crim. Action No. 09-46-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

cc: Michael J. Amador, Esq. (via ECF and first class mail)