UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION www.flsb.uscourts.gov CASE NO.: 09-34791-RBR Chapter 11 IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. JOINT EX PARTE MOTION FOR ENTRY OF STIPULATED PROTECTIVE ORDER jExnedited Relief Requested) Herbert Stettin, the Chapter 11 Trustee ("Trustee") of the Debtor, Rothstein Rosenfeldt Adler, P.A. ("RRA"), and Jeffrey Epstein, a Plaintiff in the Circuit Court of the Fifteenth Judicial Circuit in and for Palm Beach County, Florida, Jeffrey Epstein v. Scott Rothstein, et al., Case No. 50 2009CA040800XXXXMB AG (hereinafter "Epstein"), by and through undersigned counsel, do hereby file this Stipulated Protective Order ("Stipulated Protective Order") by and between the Trustee and Epstein, attached hereto as Exhibit "A", and in support thereof state: I. Pursuant to this Court's Order Granting Trustee's Motion Seeking a Protective Order and Approving Proposed Document Production Protocol ("Order") [D.E. #672], the Trustee and Epstein jointly move for the entry of the Stipulated Protective Order. 2. The Trustee and Epstein request that the Stipulated Protective Order be entered without a hearing as the relief requested herein is in compliance with the Court's Order. 3. The Trustee and Epstein are requesting expedited relief so that Epstein can quickly begin the process of reviewing and analyzing any responsive documents. EFTA00305074