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

Case 1:07-cv-00743-LJB

Document 8

Filed 10/26/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ADVANCED TECHNOLOGY SYSTEMS, INC. Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-0743C Judge Bush

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 the accompanying proposed protective order prohibiting the disclosure of confidential source selection matters, sensitive plans or specifications, and other proprietary information in accordance with the terms and conditions set forth in the proposed order. The proposed protective order is identical to the Court's sample Form 8, appropriately captioned. Plaintiff, Advanced Technology Systems, Inc., and Interventor, Perot Systems Government Services, Inc. ("Perot"), both consent to this motion. This case involves competitive procurement matters and includes proprietary and confidential pricing information, and other sensitive procurement information. Because defendant's administrative record contains protected material necessary to safeguard the competitive process, we request that all filings disclosing protected materials be under seal in this case.

Case 1:07-cv-00743-LJB

Document 8

Filed 10/26/2007

Page 2 of 3

For the foregoing reasons, defendant respectfully requests that the Court issue the attached proposed protective order.

Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/ Mark A. Melnick MARK A. MELNICK Assistant Director s/ Scott Slater SCOTT SLATER Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20005 Tel: (202) 616-0467 Fax: (202) 514-8624 October 26, 2007 Attorneys for Defendant

Case 1:07-cv-00743-LJB

Document 8

Filed 10/26/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on October 26, 2007 a copy of the foregoing "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/ Scott Slater