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

Case 1:07-cv-00830-RHH

Document 5

Filed 12/03/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST LIBERTY FRUIT COMPANY, INC., Plaintiff, v. ) ) ) ) No. 07-830C ) ) (Judge Hodges) ) ) ) )

THE UNITED STATES, Defendant.

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 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, culled directly from the forms following to 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/ Brian M. Simkin BRIAN M. SIMKIN Assistant Director

Case 1:07-cv-00830-RHH

Document 5

Filed 12/03/2007

Page 2 of 2

s/ J. Reid Prouty J. REID PROUTY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street N.W. Washington, DC 20530 Tele: (202) 305-7586 Fax: (202) 514-7969

Dated: December 4, 2007 Atch: Draft Protective Order

Attorneys for Defendant