Case 3:12-cv-30051-MAP Document 118 Filed 03/17/14 Page 1 of 2

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS SPRINGFIELD DIVISION SEXUAL MINORITIES UGANDA, Plaintiff, v. SCOTT LIVELY, individually and as president of Abiding Truth Ministries, Defendant. : : : : : : : : : : CIVIL ACTION 3:12-CV-30051-MAP JUDGE MICHAEL A. PONSOR MAGISTRATE JUDGE NEIMAN

DEFENDANT SCOTT LIVELYS OBJECTION TO PROTECTIVE ORDER Pursuant to Fed. R. Civ. P. 72(a), Defendant Scott Lively (Lively) respectfully objects to the Protective Order entered by Magistrate Judge Kenneth P. Neiman on March 3, 2014 (dkt. 106) (Protective Order), on the ground that its provisions are clearly erroneous or contrary to law. As grounds for this Objection, Lively incorporates by reference his previous Objection filed on February 28, 2014 (dkt. 104), as well as the arguments and authorities he presented in the briefing leading up to the entry of the Protective Order (dkts. 90, 96 and 98). Lively understands that the Court has already overruled his previous objections. (Dkt. 117). However, the previous objections were not directed at the Protective Order itself, but at an interim ruling (dkt. 102) that preceded it. Lively wishes to preserve these issues for appellate review, and files this Objection out of an abundance of caution, only to avoid any claim that he has waived his objections by not objecting to the Protective Order itself.

Case 3:12-cv-30051-MAP Document 118 Filed 03/17/14 Page 2 of 2

Respectfully submitted, Philip D. Moran (MA Bar # 353920) 265 Essex Street, Suite 202 Salem, Massachusetts 01970 Tel: (978) 745-6085 Fax: (978) 741-2572 Email: philipmoranesq@aol.com /s/ Horatio G. Mihet________________ Mathew D. Staver Admitted Pro Hac Vice Stephen M. Crampton Admitted Pro Hac Vice Horatio G. Mihet Admitted Pro Hac Vice LIBERTY COUNSEL P.O. Box 540774 Orlando, FL 32854-0774 800-671-1776 Telephone 407-875-0770 Facsimile court@lc.org Attorneys for Defendant Scott Lively

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was filed electronically with the Court on March 17, 2014. Service will be effectuated by the Courts electronic notification system upon all counsel or parties of record.

/s/ Horatio G. Mihet________________ Horatio G. Mihet Attorney for Defendant Scott Lively