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

Case 1:08-cv-00177-RHH

Document 9

Filed 03/25/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) ) ) ) ) ) ) ) )

MED TRENDS, INC. Plaintiff, v. UNITED STATES OF AMERICA Defendant

No.: 08-177 C (Judge Robert Hodges, Jr.)

MOTION FOR ENTRY OF PROTECTIVE ORDER The plaintiff respectfully moves this Court for entry of a protective order. The parties expect that certain information likely to be disclosed orally or in writing during the course of this litigation may be competition-sensitive or otherwise protectable and that entry of a Protective Order is necessary to safeguard the confidentiality of that information. Attached to this motion is our proposed protective order, taken without change from the Court's Rules, Form 8, p. 150, except that the current style of the case has been inserted in the appropriate places. The plaintiff is authorized to represent to the Court that counsel for the defendant has reviewed the proposed order and has no objection to the entry of the order.

Respectfully submitted,

Case 1:08-cv-00177-RHH

Document 9

Filed 03/25/2008

Page 2 of 2

s/ William T. Welch William T. Welch BARTON, BAKER, McMAHON & TOLLE, LLP 1320 Old Chain Bridge Road, Suite 440 McLean, Virginia 22101 (703) 448-1810 (ex. 22) - Telephone (703) 448-3336 - Facsimile Attorney of Record Counsel for MED Trends, Inc. Of Counsel: John R. Tolle BARTON, BAKER, McMAHON & TOLLE, LLP 1320 Old Chain Bridge Road, Suite 440 McLean, Virginia 22101 (703) 448-1810 - Telephone (703) 448-3336 - Facsimile Dated: March 25, 2008