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

Case 1:08-cv-00261-LAS

Document 34

Filed 05/20/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST WATTS-HEALY-TIBBITS, A JV, Plaintiff, v. THE UNITED STATES, Defendant, and IBC/TOA CORP., Defendant-Intervenor. ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 08-261 (Senior Judge Smith)

DEFENDANT'S MOTION FOR A PROTECTIVE ORDER Pursuant to Rule 26(c) of the Rules of the United States Court of Federal Claims, defendant respectfully requests this Court enter a protective order prohibiting the disclosure of secret, confidential, and other proprietary information in accordance with the terms and conditions set forth in the proposed protective order. Plaintiff and defendant-intervenor consent to our motion. Certain documents contained in the administrative record that we intend to file pursuant on or about May 23, 2008, involve competitive procurement matters and include proprietary and confidential pricing information, source selection information, and other sensitive procurement information. Therefore, we request that any filings that contain or discuss documents designated protected be under seal in this case. For the foregoing reasons, defendant respectfully requests that this Court issue the attached proposed protective order.

Case 1:08-cv-00261-LAS

Document 34

Filed 05/20/2008

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Respectfully submitted, GREGORY G. KASTAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director /s/ Todd M. Hughes TODD M. HUGHES Deputy Director /s/ Stephen C. Tosini STEPHEN C. TOSINI Trial Attorney Department of Justice Civil Division Commercial Litigation Branch Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 616-5196 Fax: (202) 514-7969 Attorneys for Defendant

May 20, 2008

2

Case 1:08-cv-00261-LAS

Document 34

Filed 05/20/2008

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 20th day of May 2008, a copy of "DEFENDANT'S MOTION FOR 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/ Stephen C. Tosini