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

Case 1:07-cv-00707-CFL

Document 23

Filed 09/10/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS DAVID WHALEN, et. al., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-707 (Judge Lettow)

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 hereby moves for a protective order to enable defendant to produce records protected from disclosure pursuant to the Privacy Act, 5 U.S.C. § 552a. In its initial disclosures, defendant identified documents protected from disclosure by the Privacy Act. In order to produce such documents to plaintiffs' counsel or later submit them to the Court, the Government requires a court order. See 5 U.S.C. § 552a(b)(11). Plaintiffs' counsel has represented that plaintiffs do not oppose this motion. For these reasons, defendant respectfully requests that the Court issue the proposed protective order attached to this motion. Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director

/s/ Todd M. Hughes TODD M. HUGHES Deputy Director

Case 1:07-cv-00707-CFL

Document 23

Filed 09/10/2008

Page 2 of 2

/s/ William P. Rayel Eden Brown Gaines Michael Doherty Julia Rhodes Federal Aviation Administration Office of Chief Counsel, AGC-30 600 Independence Ave., SW Suite 1E-100 Washington, DC 20591 WILLIAM P. RAYEL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Telephone: (202) 616-0302 Facsimile: (202) 307-0972 Attorneys for Defendant

September 10, 2008

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