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

Case 1:07-cv-00831-MMS

Document 12

Filed 11/30/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS INTERNATIONAL MANAGEMENT SERVICES, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) )

No. 07-831C (Judge Sweeney)

DEFENDANT'S UNOPPOSED MOTION FOR A PROTECTIVE ORDER Pursuant to Rule 26(c) of the Rules of the United States Court of Federal Claims, defendant respectfully requests that this Court enter its standard Protective Order (RCFC Forms 8, 9, and 10) prohibiting the disclosure of secret, confidential, and other proprietary information in accordance with the terms and conditions set forth in the proposed Protective Order. Counsel for plaintiff, and counsel for proposed intervenor do not oppose this motion. For the foregoing reasons, defendant respectfully requests that this Court issue the proposed Protective Order. Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director

s/ Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director

Case 1:07-cv-00831-MMS

Document 12

Filed 11/30/2007

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s/ David D'Alessandris DAVID D'ALESSANDRIS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20005 (202) 307-0139 November 30, 2007 Attorneys for Defendant

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Case 1:07-cv-00831-MMS

Document 12

Filed 11/30/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on November 30, 2007, a copy of the forgoing "DEFENDANT'S UNOPPOSED MOTION 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/ David D'Alessandris