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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA RAND PAUL, et al., Plaintiffs v.

BARACK OBAMA, et al., Defendants. ) ) ) ) ) ) ) ) )

Civil Action No. 1:14-cv-262 - RJL

JOINT STIPULATED SETTLEMENT ORDER WHEREAS, Plaintiffs and Class Members allege that the Defendants Mass Associational Tracking Program violates the Fourth Amendment to the Constitution, as set forth in their First Amended Class Action Complaint for Declaratory & Injunctive Relief; and WHEREAS, Defendants deny that the Mass Associational Tracking Program violates the Fourth Amendment to the Constitution; and WHEREAS, without admitting liability, wrongdoing, or otherwise waiving any legal rights they may have, the Parties wish to settle this matter with prejudice; and THEREFORE, IT IS HEREBY ORDERED THAT: 1. The Class as defined in the First Amended Class Action Complaint is hereby certified; 2. Defendants will verifiably, permanently cease and desist from conducting or operating the Mass Associational Tracking Program as of ____________, 2014, and the parties shall certify in writing when this has been verified; 3. Defendants will verifiably, permanently purge from their possession, custody, and control all of the telephone metadata seized, stored, retained, and searched about Plaintiffs and Class Members pursuant to the Mass Associational Tracking Program as of _______,

2014, regardless of where held, or by whom, except for such particularized data retained pursuant to lawful warrant or court order separate from such orders authorizing the Mass Associational Tracking Program, and the parties shall certify in writing when this has been verified; 4. The federal government will obtain metadata in the future only on a particularized basis pursuant to a lawful warrant or court order; 5. Plaintiffs and Class Members have legitimate privacy interests based at least in both contract and statute in the business records related to their own accounts with their telephone service providers, even though such records are held by their telephone service providers; and 6. The Court shall retain jurisdiction of this matter until each term of settlement is completed, and 2 and 3, above are verified.

Date: ___________________

___________________________ RICHARD J. LEON United States District Judge

Agreeing on behalf of the Plaintiffs:

___________________________ Earl Trey Mayfield Michael P. Lewis Kenneth T. Ken Cuccinelli, II Counsel for Plaintiffs

Dated: __________________________

Agreeing on behalf of the Defendants:

__________________________ Ronald C. Machen Jr. U.S. Attorney for the District of Columbia James J. Gilligan Special Litigation Counsel Civil Division, Federal Programs Branch U.S. Department of Justice Counsel for Defendants

Dated: __________________________