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

Case 1:07-cv-00280-LJB

Document 11

Filed 05/18/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

IRONCLAD/EEI, A JOINT VENTURE Plaintiff, v.

THE UNITED STATES, Defendant.

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No. 07-280C (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 protective order. The proposed protective order is the same as the sample found as Form 8 of the Rules of the United States Court of Federal Claims. Plaintiff consents to this motion. This case involves competitive procurement matters and includes proprietary and confidential pricing information, source selection information, and other sensitive procurement information. Thus, because defendant's administrative record contains protected materials necessary to safeguard the competitive process, we request that all filings that disclose protected materials be under seal in this case. For the foregoing reasons, defendant respectfully requests that this Court issue the attached proposed protective order.

Case 1:07-cv-00280-LJB

Document 11

Filed 05/18/2007

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director /s/ Bryant G. Snee BRYANT G. SNEE Deputy Director

/s/ Carrie A. Dunsmore CARRIE A. DUNSMORE Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20005 Tel. (202) 305-7576 Fax. (202) 514-8624-0972 May 18, 2007 Attorneys for Defendant

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Case 1:07-cv-00280-LJB

Document 11

Filed 05/18/2007

Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on this 18th day of May, 2007, a copy of the 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/Carrie A. Dunsmore Carrie A. Dunsmore