USA v. STONE

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)

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: [phone]

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

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