Free Motion for Protective Order - District Court of Federal Claims - federal

Case 1:01-cv-00570-MCW

Document 165

Filed 07/26/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BLUE LAKE FOREST PRODUCTS, INC., ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) TIMBER PRODUCTS COMPANY, Plaintiff, v. THE UNITED STATES, Defendant. CLR TIMBER HOLDINGS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 01-570C (Judge Williams)

No. 01-627C (Judge Williams)

No. 04-501C (Judge Williams)

DEFENDANT'S UNOPPOSED MOTION FOR A PROTECTIVE ORDER Pursuant to Rule 26(c) of the Rules of the United States Court of Federal Claims and the Scheduling Order issued on July 25, 2007, defendant respectfully requests that this Court enter the accompanying proposed protective order prohibiting the disclosure of information in accordance with the terms and conditions set forth in the proposed protective order. Plaintiff consents to this motion. The protective order relates to seven (7) documents defendant produced in redacted form,

Case 1:01-cv-00570-MCW

Document 165

Filed 07/26/2007

Page 2 of 3

and plaintiff seeks to review the unredacted version of each document. The redacted portions relate to personal matters, or privileged information for these cases or others for which defendant believes privilege has not been waived. Thus, we request the protective order for the redacted portions of the seven (7) documents. For the foregoing reasons, defendant respectfully requests that this Court issue the attached proposed protective order. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director /s/ Kathryn A. Bleecker KATHRYN A. BLEECKER /s/ Ellen M. Lynch ELLEN M. LYNCH Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20005 Tel: (202) 353-7994 Fax: (202) 514-8624 July 26, 2007 Attorneys for Defendant

Case 1:01-cv-00570-MCW

Document 165

Filed 07/26/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 26th day of July, 2007, a copy of the Defendant's Unopposed Motion For a Protective Order was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

/s/ Ellen M. Lynch Ellen M. Lynch