Free Motion to Unseal Document - District Court of Federal Claims - federal

Case 1:08-cv-00261-LAS

Document 31

Filed 05/07/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST

WATTS-HEALY TIBBITTS A JV Plaintiff, v. THE UNITED STATES, Defendant. and IBC/TOA Corporation Intervenor.

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No. 08-261C (Senior Judge Smith)

MOTION FOR LIMITED WAIVER OF DOCUMENTS FILED UNDER SEAL Plaintiff requests the Court to grant a limited right to Intervenor to access certain documents filed under seal in this matter. Plaintiff WATTS-HEALY TIBBITTS A JV filed its Motion For Reconsideration Of Order Of April 25, 2008, Denying Preliminary Injunction Relief, and its Second Motion for Preliminary Injunctive Relief, Based On Additional Grounds Contained in Amended Complaint, its Amended Complaint For Temporary Restraining Order, Preliminary and Permanent Injunctive Relief, and a Memorandum of Points and Authorities in Support thereof on May 5, 2008. These documents were all filed under seal. On May 6, 2008, following a Status Report Conference Call, counsel for Defendant Intervenor IBC/TOA Corporation requested that it be permitted to show the aforementioned sealed documents to their client in order to file an appropriate response. Plaintiff has no objection to counsel for Defendant-Intervenor sharing this

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Case 1:08-cv-00261-LAS

Document 31

Filed 05/07/2008

Page 2 of 2

information with its client for that purpose. Plaintiff respectfully requests the Court to grant waiver for this purpose.

Respectfully submitted,

Date: May 6, 2008

/s/ Michael H. Payne Michael H. Payne, Esquire Payne Hackenbracht & Sullivan 220 Commerce Dr., Suite 100 Ft. Washington, PA 19034 215-542-2777/215-5422779(fax) Attorney of Record for WATTS-HEALY TIBBITTS, A JOINT VENTURE

Of Counsel: Joseph A. Hackenbracht, Esquire Timothy A. Sullivan, Esquire Payne Hackenbracht & Sullivan

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