Case 2:12-cr-00163-DN-BCW Document 27 Filed 08/24/12 Page 1 of 3

DAVID B. BARLOW, United States Attorney (No. 13117) ADAM S. ELGGREN, Assistant United States Attorney (No. 11064) Attorneys for the United States of America 185 South State Street, Suite 300 Salt Lake City, Utah 84111 Telephone: (801) 524-5682 ________________________________________________________________________ IN THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH, NORTHERN DIVISION ________________________________________________________________________ UNITED STATES OF AMERICA, Plaintiff, v. JOHN ANTHONY BORELL III, Defendant. : : : : : Judge David O. Nuffer Magistrate Judge Brooke C. Wells Case No. 2:12-CR-163 DN-BCW STIPULATED MOTION FOR PROTECTIVE ORDER.

________________________________________________________________________

The United States of America, by and through the undersigned Assistant United States Attorney, after discussions with attorneys for the Defendant, respectfully moves this Court, pursuant to Rule 16, Fed.R.Crim.P., to enter the attached Stipulated Protective Order concerning the disclosure and dissemination of documents provided in discovery.

Case 2:12-cr-00163-DN-BCW Document 27 Filed 08/24/12 Page 2 of 3

BACKGROUND Defendant John Anthony Borell III was indicted by the Grand Jury on April 4, 2012, on two counts of Computer Intrusion, violations of 18 U.S.C. 1030(a)(5)(A) (Dkt. No. 4). Since his initial appearance on April 16, 2012 in Federal Court in the District of Utah, Borell and his attorneys have been provided discovery by the government on four occasions (Dkt. Nos. 18, 24-26). Because discovery provided to date is voluminous and contains a great deal of third-party personal information such as phone numbers, addresses, and the like, the parties in this case have stipulated to the attached protective order covering the contents of all discovery, to assist in the rapid dissemination and analysis of the discovery while still protecting innocent parties. WHEREFORE the government respectfully moves this Court issue the attached protective order. SUBMITTED this 24th day of August, 2012.

DAVID B. BARLOW United States Attorney

/s/ Adam S. Elggren _________________________________ ADAM S. ELGGREN Assistant United States Attorney

Case 2:12-cr-00163-DN-BCW Document 27 Filed 08/24/12 Page 3 of 3

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that I am an employee of the United States Attorney's Office, and that a copy of the foregoing STIPULATED MOTION FOR PROTECTIVE ORDER was faxed, electronically delivered, or mailed, postage prepaid, to all parties named below, this 24th day of August, 2012.

Jamie Zenger and Parker Douglas Assistant Federal Defenders Attorneys for Defendant 46 West Broadway #110 Salt Lake City, Utah 84101

/s/ Adam S. Elggren _____________________