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

Case 1:07-cv-00777-SGB

Document 17

Filed 08/08/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

METCALF CONSTRUCTION COMPANY, INC., Plaintiff, v. THE UNITED STATES, Defendant.

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No. 07-777C (Judge Braden)

DEFENDANT'S CONSENT MOTION FOR ENTRY OF A PROTECTIVE ORDER Defendant, the United States, respectfully requests that the Court enter the attached "Protective Order." Counsel for the plaintiff, Metcalf Construction Company, Inc. ("Metcalf"), has authorized us to state that Metcalf consents to this motion. Counsel for both parties have been working cooperatively to facilitate the exchange of a large volume of documents. Certain information likely to be disclosed during the course of this litigation may be competition-sensitive or otherwise protectable and, thus, entry of a protective order is necessary to safeguard the confidentiality of that information. Our motion is in the interests of justice and judicial economy. We respectfully request that our consent motion for entry of a protective order be granted. Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director /s/ Reginald T. Blades, Jr. REGINALD T. BLADES, JR. Assistant Director

Case 1:07-cv-00777-SGB

Document 17

Filed 08/08/2008

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/s/ David S. Silverbrand DAVID S. SILVERBRAND Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street Washington, D.C. 20530 Tel: (202) 305-3278 Fax: (202) 353-7988 August 8, 2008 Attorneys for Defendant

Case 1:07-cv-00777-SGB

Document 17

Filed 08/08/2008

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on August 8, 2008, a copy of the foregoing "DEFENDANT'S CONSENT MOTION FOR ENTRY OF 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 S. Silverbrand