Filing 18

Unopposed MOTION for Protective Order Governing Discovery by USA as to ROGER JASON STONE, JR. (Attachments: # 1 Text of Proposed Order)(Zelinsky, Aaron)

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA v. ROGER JASON STONE, JR., Crim. No. 19-018 (ABJ) Defendant. UNOPPOSED MOTION FOR PROTECTIVE ORDER GOVERNING DISCOVERY Pursuant to Rule 16(d) of the Federal Rules of Criminal Procedure, the United States of America, by and through Special Counsel Robert S. Mueller, III, hereby moves for entry by this Court of a protective order that will ensure the confidentiality of personal identification information and discovery that are included within the materials to be produced by the government pursuant to its discovery obligations. Entry of a protective order restricting the use, dissemination, and disposition of such documents is essential to permit the United States to provide discovery to the defendant while protecting, among other things, personal information and other confidential materials. The United States has conferred with counsel for the defendant, Roger J. Stone, Jr., and the defendant consents to the proposed Protective Order, a copy of which is submitted with this application. WHEREFORE, the government respectfully moves the Court to enter the proposed Protective Order Governing Discovery. Respectfully submitted, ROBERT S. MUELLER III Special Counsel JESSIE K. LIU United States Attorney By: /s/Aaron Zelinsky Jeannie S. Rhee Aaron S.J. Zelinsky U.S. Department of Justice The Special Counsel’s Office 950 Pennsylvania Avenue NW Washington, D.C. 20530 Telephone: (202) 616-0800 By: /s/ Jonathan Kravis Michael J. Marando Assistant United States Attorneys 555 Fourth Street N.W. Washington, D.C. 20530 Attorneys for the United States of America Dated: January 31, 2019 2

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