UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION www.flsb.uscourts.gov CASE NO.: 09-34791-RBR Chapter 11 WI RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. JOINT EX PARTE MOTION FOR ENTRY OF STIPULATED PROTECTIVE ORDER (Expedited Relief Requested) Herbert Stettin, the Chapter 11 Trustee ("Trustee") of the Debtor, Rothstein RosehfeldtAdler, P.A. ("RRA"), and Jeffrey Epstein, by and through this undersigned counsel, Fowler White Burnett, move for the entry of Stipulated Protective Order ("Stipulated Protective Order") by and between the Trustee and Mr. Epstein's counsel, attached hereto as Exhibit "A", and in support thereof state: 1. 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 Mr. Epstein, through counsel, jointly move for the entry of the Stipulated Protective Order. 2. The Trustee and Mr. Epstein, through counsel, 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 Mr. Epstein, through counsel, are requesting expedited relief so that Creditors can quickly begin the process of reviewing and analyzing voluminous information. WHEREFORE, the Trustee and Mr. Epstein, through counsel, jointly move for the entry of EFTA00593799