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

Case 1:07-cv-00151-MBH

Document 23-3

Filed 05/07/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS UNITED STATES FIRE INS. CO., ) ) Plaintiff, ) v. ) ) UNITED STATES, ) ) Defendant. ) ____________________________________)

(Judge Horn)

ACKNOWLEDGMENT OF PRIVACY ACT PROTECTIVE ORDER I, , hereby acknowledge that I have read and

understand the Privacy Act Protective Order entered in this action. I hereby agree to be bound by the terms of the Order. Specifically: 1. I agree that I will use records and information protected by the Order only

for purposes of this litigation, including any appeals, and not for any other purpose of any kind, including that I will not disclose any such records or information to the public. 2. I agree that I will return all records subject to this order produced by the

defendant to defendant's counsel at the termination of this litigation. I also agree to destroy or redact, or to return to defendant's counsel for destruction or redaction, any records created that contain information subject to this Order, within thirty days after the termination of this litigation. 3. I will certify to the defendant that any documents created that contain

information subject to this Order have been destroyed or redacted within forty-five days after the termination of this litigation. 4. I agree that I will disclose records and information protected by the Order

solely to the Court (under seal), the attorneys of record in this litigation, persons regularly

Case 1:07-cv-00151-MBH

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Filed 05/07/2008

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in the employ of such attorneys, and any experts or consultants hired for this case by the parties or their attorneys and who (except the Court, defendants' employees and defendants' counsel) have signed an acknowledgment like this one and have a need for such information to perform duties specifically related to the conduct of this litigation. 5. Should I wish to disclose the records which are subject to the Order to any

additional persons except those indicated in the Order and herein, I will first seek the defendant's consent. If the defendant does not consent to the disclosure, then I may, on motion, seek modification of the Order from the Court. 6. I agree that any documents or information subject to the Order may not be

disclosed in open Court, including as or through trial exhibits or through a public filing (e.g., a pleading, motion, exhibit or expert report) without first obtaining consent of the Court. I further agree that those portions of any filings that contain Privacy Act

information subject to this Order shall be filed under seal and may not be filed publicly without leave of the Court. 7. I hereby confirm that my duties under this Acknowledgment shall survive

the termination of this case and are binding upon me for all time. 8. I hereby consent to the personal jurisdiction of the United States Court of

Federal Claims in the above-captioned case for the purpose of enforcing the aforementioned Order.

[signature]

Case 1:07-cv-00151-MBH

Document 23-3

Filed 05/07/2008

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DATED: