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

Case 1:08-cv-00063-GWM

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Filed 09/16/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS THOMAS STINE, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 08-63 C (Judge G. Miller)

DEFENDANT'S MOTION UPON BEHALF OF THE PARTIES FOR A PROTECTIVE ORDER Defendant, upon behalf of the parties, respectfully requests that this Court issue the appended protective order to permit the parties to submit filings under seal. Mr. Stine's counsel reviewed this motion and authorized Government counsel to state that Mr. Stine joins in this motion. As discussed at the September 5, 2008 status conference, anticipated filings in this case will contain sensitive personal and medical information. Government counsel understands that Mr. Stine desires that his sensitive personal and medical information remain private. Given the nature of these filings, the Government believes that Mr. Stine's privacy interests outweigh the general public interest in open proceedings. For the reasons stated above, the parties request that the Court enter an order to permit filings designated as FILED UNDER SEAL to be filed under seal

Case 1:08-cv-00063-GWM

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Filed 09/16/2008

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and that such filings shall remain under seal absent further order of the Court. A proposed order is appended.

Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director Kirk T. Manhardt Assistant Director OF COUNSEL: LCDR Marc S. Brewen JAGC, USN Office of the Judge Advocate General /s/ John. S. Groat JOHN S. GROAT Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 616-8260 Fax: (202) 514-7965 [email protected] September 16, 2008 Attorneys for Defendant -2-

Case 1:08-cv-00063-GWM

Document 16

Filed 09/16/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS THOMAS STINE, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) PROTECTIVE ORDER Based upon the parties' representations in moving for the entry of this order, the Court orders that (1) the parties may submit filings designated by the parties as FILED UNDER SEAL under seal, and (2) filings designated by the parties as FILED UNDER SEAL shall remain under seal absent further order of the Court. No. 08-63 C (Judge G. Miller)

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Case 1:08-cv-00063-GWM

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Filed 09/16/2008

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CERTIFICATE OF FILING I hereby certify that on September 16, 2008, a copy of the foregoing DEFENDANT'S MOTION UPON BEHALF OF THE PARTIES FOR A PROTECTIVE ORDER was filed electronically. 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/John S. Groat