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

Case 1:07-cv-00237-JPW

Document 9

Filed 04/20/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CIRCLE LINE ­STATUE OF LIBERTY FERRY, INC. Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-237C (Judge Wiese)

MOTION FOR 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 a protective order prohibiting the disclosure of secret, confidential, and other proprietary information in accordance with the terms and conditions set forth in the proposed protective order and grant Plaintiff=s counsel access to information subject to the order. Given the filing schedule established by the Court, the

standard order has been modified to permit immediate access to Circle Line counsel upon completion of the Application. Based on several communications with counsel for Circle Line,

Circle Line appears to oppose the relief requested in this motion. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director BRYANT G. SNEE Deputy Director

Case 1:07-cv-00237-JPW

Document 9

Filed 04/20/2007

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s/ Gregg M. Schwind GREGG M. SCHWIND Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit 8th Floor 1100 L St., NW Washington, D.C. 20530 Attorneys for Defendant April 20, 2007

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Case 1:07-cv-00237-JPW

Document 9

Filed 04/20/2007

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