Free Motion for Discovery - District Court of Federal Claims - federal

Case 1:01-cv-00495-EGB

Document 303

Filed 12/13/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS KENT CHRISTOFFERSON et al., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 01-495C (Senior Judge Bruggink)

JOINT MOTION FOR ENTRY OF DISCOVERY ORDER The parties respectfully request that the Court enter the attached "Discovery Order," which the parties believe is in the interests of justice and judicial economy. Counsel for both parties have been working cooperatively to facilitate defendant's review of the questionnaires prepared by plaintiffs pursuant to the parties Memorandum of Understanding. The purpose of the proposed order, originally suggested by the Court, is to permit defendant to have prompt access to the questionnaires, yet provide a mechanism for recovering privileged information disclosed as part of their disclosure. Defendant has retained a copy service, which is standing by in San Francisco waiting to copy these questionnaires. For these reasons, the parties respectfully request that this motion for entry of discovery order be granted. Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General

s/ Jeanne E. Davidson JEANNE E. DAVIDSON Director

Case 1:01-cv-00495-EGB

Document 303

Filed 12/13/2007

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s/ Jack W. Lee JACK W. LEE Minami Tamaki LLP 360 Post St. 8th Floor San Francisco, CA 94108-4903 Tel: 415-788-9000

s/ Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 2nd Floor, Todd Bldg. Washington, D.C. 20530 Tele: (202) 616-2311

Attorneys for Plaintiffs Date: December 13, 2007

Attorneys for Defendant Date: December 13, 2007

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Case 1:01-cv-00495-EGB

Document 303

Filed 12/13/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that, on December 13, 2007, a copy of the foregoing 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/ Steven J. Gillingham