Free Motion to Expedite - District Court of Federal Claims - federal

Case 1:08-cv-00238-TCW

Document 52

Filed 06/30/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS (BID PROTEST) AMERICAN ORDNANCE LLC, Plaintiff, vs. THE UNITED STATES, Defendant, and BAE SYSTEMS ORDNANCE SYSTEMS INC., Defendant-Intervenors. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 08-238C Judge Wheeler

UNOPPOSED MOTION FOR EXPEDITED CONSIDERATION OF APPLICATIONS FOR ACCESS TO INFORMATION UNDER PROTECTIVE ORDER BY OUTSIDE COUNSEL Plaintiff American Ordnance LLC, by undersigned counsel, hereby respectfully renews its June 27, 2008 Motion for Expedited Consideration of Applications for Access to Information Under Protective Order by Outside Counsel, seeking expedited admission under the Protective Order for Justin A. Chiarodo, Esq. and David Yang, Esq., attorneys with Dickstein Shapiro LLP. Since filing its June 27 Motion, Plaintiff sought and received consent from counsel for the United States and BAE Systems Ordnance Systems, Inc. for the expedited approval of Mr. Chiarodo and Mr. Yang's Protective Order applications. A proposed order is attached.

DSMDB-2463344

Case 1:08-cv-00238-TCW

Document 52

Filed 06/30/2008

Page 2 of 5

Respectfully submitted, Dated: June 30, 2008 Of Counsel: Michael J. Askew Telephone: (202) 420-3513 Email: [email protected] Joseph R. Berger Telephone: (202) 420-3673 Email: [email protected] DICKSTEIN SHAPIRO LLP 1825 Eye Street, N.W. Washington, D.C. 20006 /s/ Stuart B. Nibley DICKSTEIN SHAPIRO LLP 1825 Eye Street, N.W. Washington, D.C. 20006 Telephone: (202) 420-3701 Protected Fax: (202) 822-9544 Email: [email protected] Attorney of Record for Plaintiff, American Ordnance LLC

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DSMDB-2463344

Case 1:08-cv-00238-TCW

Document 52

Filed 06/30/2008

Page 3 of 5

IN THE UNITED STATES COURT OF FEDERAL CLAIMS (BID PROTEST) AMERICAN ORDNANCE LLC, Plaintiff, vs. THE UNITED STATES, Defendant, and BAE SYSTEMS ORDNANCE SYSTEMS INC., Defendant-Intervenors. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 08-238C Judge Wheeler

ORDER For the reasons set forth in Plaintiff American Ordnance LLC's Unopposed Motion for Expedited Consideration of Applications for Access to Information Under Protective Order by Outside Counsel, it is hereby: ORDERED, that the Plaintiff's Unopposed Motion for Expedited Consideration of Applications for Access to Information Under Protective Order by Outside Counsel is GRANTED; and ORDERED, that Justin A. Chiarodo, Esq. and David Yang, Esq., of Dickstein Shapiro LLP, are hereby granted access to protected information pursuant to the Court's April 4, 2008 Protective Order in this case, effective immediately.

Dated: __________

________________________ Judge Thomas C. Wheeler

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DSMDB-2463344

Case 1:08-cv-00238-TCW

Document 52

Filed 06/30/2008

Page 4 of 5

Copies To: Stuart B. Nibley Dickstein Shapiro LLP 1825 Eye Street, NW Washington, DC 20006 Joan Margaret Stentiford U.S. Department of Justice 1100 L St., NW 8th Floor Washington, DC 20530 Drew A. Harker Arnold & Porter LLP 555 Twelfth Street, N.W. Washington, D.C. 20004

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DSMDB-2463344

Case 1:08-cv-00238-TCW

Document 52

Filed 06/30/2008

Page 5 of 5

CERTIFICATE OF ELECTRONIC FILING I hereby certify that on this 30th day of June, 2008, a copy of the foregoing UNOPPOSED MOTION FOR EXPEDITED CONSIDERATION OF APPLICATIONS FOR ACCESS TO INFORMATION UNDER PROTECTIVE ORDER BY OUTSIDE COUNSEL was filed electronically under seal. 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/ Joseph R. Berger

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DSMDB-2463344