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

Case 1:08-cv-00118-NBF

Document 35

Filed 05/06/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS OMEGA WORLD TRAVEL, INC., Plaintiff, v. THE UNITED STATES, Defendant, v. CW GOVERNMENT TRAVEL, INC., Intervenor. ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 08-118C (Judge Firestone)

BID PROTEST

PLAINTIFF'S UNOPPOSED EMERGENCY MOTION TO SEAL ITS MAY 5, 2008 RESPONSE TO "CW GOVERNMENT TRAVEL, INC.'S MOTION TO DISMISS, AND IN THE ALTERNATIVE, MOTION FOR JUDGMENT UPON THE ADMINISTRATIVE RECORD" Plaintiff, Omega World Travel, Inc. ("Omega"), respectfully requests that this Court seal its May 5, 2008 response to "CW Government Travel, Inc.'s Motion to Dismiss, and in the Alternative, Motion for Judgment Upon the Administrative Record." As the result of a mistake, the aforementioned brief was not filed under seal. That brief may contain some information that is subject to this Court's protective order that should be sealed. As such, pursuant to Part 4 of Appendix C of the Rules of the Court of Federal Claims, Plaintiff respectfully requests that its May 5, 2008 response to "CW Government Travel, Inc.'s Motion to Dismiss, and in the Alternative, Motion for Judgment Upon the Administrative Record" be sealed. Counsel for Intervenor has indicated that it is unopposed to this motion. Counsel for Defendant has indicated that it is unopposed to this motion. WHEREFORE, Plaintiff respectfully requests that this Court grant this motion to seal and order that its May 5, 2008 Response to "CW Government Travel, Inc.'s Motion to Dismiss, and in

Case 1:08-cv-00118-NBF

Document 35

Filed 05/06/2008

Page 2 of 2

the Alternative, Motion for Judgment Upon the Administrative Record," and any documents attached thereto, be sealed from the public view. Respectfully submitted, NEEL, HOOPER & BANES, P.C. By: ___________________________________ Bryant S. Banes Sean D. Forbes Neel, Hooper & Banes, PC 1800 West Loop South, Suite 1400 Houston, Texas 77027-3008 Tel: (713) 629-1800 Fax: (713) 629-1812 Counsel for Plaintiff May 6, 2008 CERTIFICATE OF FILING I hereby certify that on this 6th day of May, 2008, a copy of the foregoing "Plaintiff's Unopposed Emergency Motion to Seal its May 5, 2008 Response to `CW Government Travel, Inc.'s Motion to Dismiss, and in the Alternative, Motion for Judgment Upon the Administrative Record'" was electronically filed. 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 the filing through the Court's system.

s/ Bryant Banes