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

Case 1:08-cv-00101-LJB

Document 7

Filed 02/26/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS L-3 GLOBAL COMMUNICATIONS SOLUTIONS, INC., Plaintiff, v. ) ) ) ) ) ) ) ) ) ) )

No. 08-101C (bid protest) (Judge Bush)

THE UNITED STATES, Defendant.

DEFENDANT'S UNOPPOSED MOTION FOR PROTECTIVE ORDER With the consent of plaintiff, we respectfully request that the Court issue its standard protective order in this case. The administrative record that is being prepared for this case includes proprietary and competition-sensitive information, the public release of which potentially would prejudice the Government and those parties that bid upon the contract that is the subject of this protest. Accordingly, we respectfully request that the Court issue a protective order. A proposed protective order, taken from the forms following the Court's rules and modified to include the proper caption, is attached. Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director

s/ Deborah A. Bynum DEBORAH A. BYNUM Assistant Director

Case 1:08-cv-00101-LJB

Document 7

Filed 02/26/2008

Page 2 of 2

s/ Dawn S. Conrad DAWN S. CONRAD Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, DC 20530 Tel: (202) 616-2279 Fax: (202) 305-7643

Dated: February 26, 2008

Attorneys for Defendant

Attachment: Draft Protective Order

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