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

Case 1:07-cv-00867-TCW

Document 13

Filed 04/16/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

AMERICAN ORDNANCE LLC, Plaintiff, vs. UNITED STATES, Defendant. Case No. 07-867C Judge Wheeler

UNOPPOSED MOTION TO SEAL APRIL 4, 2008 HEARING TRANSCRIPT Plaintiff, American Ordnance LLC ("AO"), respectfully moves the Court to file under seal the Transcript of the Hearing conducted on April 4, 2008 in the abovecaptioned Case No. 07-867C [Docket No. 12]. The referenced hearing took place prior to entry of a Protective Order in a related case, Case No. 08-238C (the "Bid Protest Case"). Counsel for AO in the Bid Protest Case ("Bid Protest Counsel") has identified one piece of information (the "Proprietary Information"), appearing at pages 13 and 15 of the April 4 Transcript, that should be treated as proprietary to AO. Bid Protest Counsel has designated this information as protected in AO's Bid Protest Complaint, and the Bid Protest Complaint is filed under seal. A redacted version of the April 4, 2008 Transcript is filed herewith as Exhibit A. Certificate of Conference. Bid Protest Counsel, counsel in the above-captioned case, and counsel for the United States, Ms. Joan Stentiford, conferred regarding this motion. The United States, the only other party to the above-captioned action and the

Case 1:07-cv-00867-TCW

Document 13

Filed 04/16/2008

Page 2 of 2

Bid Protest Case, does not oppose AO's proposal that the Proprietary Information be treated as protected information. A proposed form of order is attached hereto as Exhibit B for the Court's consideration. WHEREFORE, AO respectfully requests that the unredacted version of the April 4, 2008 Transcript lodged in the Clerk's office be placed under seal. Respectfully submitted this 16th day of April, 2008. s/ Steven M. Masiello Steven M. Masiello McKenna Long & Aldridge LLP 1875 Lawrence Street, Suite 200 Denver, CO 80202 (303) 634-4000 Facsimile: (303) 634-4400 E-mail: [email protected] ATTORNEY FOR PLAINTIFF, AMERICAN ORDNANCE LLC

Of Counsel: Timothy R. Odil McKenna Long & Aldridge LLP 1875 Lawrence Street, Suite 200 Denver, CO 80202 (303) 634-4000 Facsimile: (303) 634-4400 E-mail: [email protected]

DN:32140732.1

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