Movant Barry D. Romeril moves pursuant to Fed. R. Civ. P. 60(b)(4) for relief from the
final judgment’s prohibition of his future truthful speech about this case. Paragraph 11 of the
Consent of Barry D. Romeril (“Consent”) incorporated into the final judgment is void because it
is an unconstitutional prior restraint and a content-based restriction on speech that violates the
First Amendment of the U.S. Constitution, and for other reasons more fully set forth below. An
Amended Consent Order omitting the offending gag provision has been submitted as part of this
Motion.

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