UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS


UNITED STATES OF AMERICA )
)
v. ) 1:14-CR-10221-WGY
)
MICHAEL AFFA, )
ANDREW AFFA, )
MITCHELL BROWN, )
CHRISTOPHER PUTNAM, and )
CHRISTOPHER NIX )

DEFENDANTS JOINT AND ASSENTED TO MOTION TO
EXTEND DATE TO FILE PROTECTIVE ORDER SUBMISSIONS

Defendants jointly and with the governments assent move to
enlarge the time for the parties to file a proposed protective
order, with any remaining disagreements redlined, until
September 25, 2014. At the status conference on September 11,
2014, the Court ordered the government to file a proposed
protective order, with any objections by Defendants redlined, by
September 18, 2014. Since that time, the parties have engaged in
discussions about the protective order and have attempted in
good faith to reach agreement, including a conference call on
September 15
th.
Further constructive discussions today resulted in
numerous alternative proposals which have not yet been reviewed
by all counsel due to the number of counsel and their
conflicting schedules.



Case 1:14-cr-10221-WGY Document 49 Filed 09/18/14 Page 1 of 3
- 2 -



MICHAEL AFFA ANDREW AFFA
By his attorney, By his attorney,
/s/ Robert M. Goldstein /s/ Steven E. Losquadro
Robert M. Goldstein, Esq. Steven E. Losquadro, P.C.
Mass. Bar. 630584 N.Y. Atty. Reg. 2349173
20 Park Plaza, Suite 1000 649 Route 25A, Suite 4
Boston, MA 02116 Rocky Point, NY 11778
(617) 742-9015 (631) 744-9070
rmg@goldstein-lawfirm.com losquadrolaw@aol.com

MITCHELL BROWN CHRISTOPHER PUTNAM
By his attorneys, By his attorney,
/s/ Richard Roth /s/ Joshua Hanye
/s/ Danielle Pomeraniec Joshua R. Hanye
Richard Roth Mass. Bar 661686
Danielle Pomeraniec Federal Defenders Office
Roth Law Firm 51 Sleeper St., 5
th
Floor
295 Madison Avenue, Floor 22 Boston, MA 02210
New York, NY 10017 (617) 223-8061
(212) 542-8882 joshua_hanye@fd.org
rich@rrothlaw.com
danielle@rrothlaw.com
CHRISTOPHER NIX
By his attorney,
/s/ Jonathan L.Kotlier
Jonathan L. Kotlier, Esq.
Mass. Bar 545491
Nutter, McLennen & Fish, LLP
Seaport West
155 Seaport Blvd.
Boston, MA 02210
(617) 439-2000
jkotlier@nutter.com





Case 1:14-cr-10221-WGY Document 49 Filed 09/18/14 Page 2 of 3
- 3 -


CERTIFICATE OF SERVICE

I, Joshua R. Hanye, hereby certify that this document filed
through the ECF system will be sent electronically to the
registered participants as identified on the Notice of
Electronic Filing (NEF) on September 18, 2014.


/s/ Joshua R. Hanye
Joshua R. Hanye




Case 1:14-cr-10221-WGY Document 49 Filed 09/18/14 Page 3 of 3