ORDERED in the Southern District of Florida on Raymond B. Ray, Judge United States Bankruptcy Court 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. STIPULATED PROTECTIVE ORDER BY AND BETWEEN TRUSTEE AND CREDITORS 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, P.A., pursuant to this Court's May 18, 2010 oral ruling granting Trustee's Motion for Expedited Relief Seeking a Protective Order and Approving Proposed Document Production Protocol ( D.E. #617), hereby agree to and request Court approval of the following stipulation: It is expected that, to facilitate the sharing of RRA's information, including electronically stored information ("ESI"), Mr. Epstein's counsel has submitted search criteria, including names of targeted custodians, search terms, date ranges, to/from, subject line contents, or other criteria to the Trustee to be applied against ESI in the possession of the Trustee. It is further anticipated that the Trustee's counsel and Mr. Epstein's counsel have agreed upon certain search criteria prior to the resulting data being produced to MR. Epstein's counsel. Finally, both parties seek the protection of EFTA00593803