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TII

06/25/15 2:56 PM

#304309 RE: Donotunderstand #304306

Not sure, as most everything recently is under seal, but there's a new filing by the Fairholme lawyers just in the last few hours. It's doc. # 168 (52 pages) and titled...


PLAINTIFFS’ PUBLIC REDACTED MOTION AND BRIEF IN SUPPORT OF MOTION

TO REMOVE THE “PROTECTED INFORMATION” DESIGNATIONS

FROM THE DEPOSITIONS OF EDWARD DEMARCO AND MARIO UGOLETTI

____________________________________________
CONCLUSION
For the foregoing reasons, Plaintiffs respectfully request that the Court enter an order requiring
that the Government remove the “Protected Information” designation from the Ugoletti
and DeMarco Depositions. If the Court does not believe such relief is appropriate, then Plaintiffs
respectfully request that the Court order the “Protected Information” designation removed from
those specific portions of the Depositions that Plaintiffs have identified in Exhibits G and H. Finally,
in the alternative, Plaintiffs respectfully request that this Court exercise its power under
Paragraph 18 of the Protective Order and authorize the filing of the Depositions under seal in the
Fairholme Funds, Inc. v. The Federal Housing Finance Agency D.C. Circuit litigation, and in
any other action challenging the Net Worth Sweep in which Plaintiffs are participating either as
parties or amici, to ensure that the courts are not presented with a misleading and incomplete factual
record.


I haven't read it all yet.