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

Case 1:07-cv-00155-CFL

Document 12

Filed 03/15/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS Bid Protest

GEO-SEIS HELICOPTERS, INC., Plaintiff, v. THE UNITED STATES, Defendant, and PRESIDENTIAL, AIRWAYS, INC. Defendant-Intervenor.

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Civil Action No. 07-155 (Judge Lettow)

UNOPPOSED MOTION FOR PROTECTIVE ORDER BY PRESIDENTIAL AIRWAYS, INC. Pursuant to Rule 26(c) of the Rules of the United States Court of Federal Claims ("RCFC"), Defendant-Intervener Presidential Airways, Inc. ("Presidential") respectfully requests that this Court enter a protective order in the form attached prohibiting the disclosure of secret, confidential, and other proprietary information in accordance with the terms and conditions set forth in the proposed protective order. This proposed order is identical to the order set forth at Form 8 of the RCFC, with the exception of an additional sentence in paragraph 2.d. that provides for the immediate admission of the counsel previously admitted at GAO without further action. Counsel for Presidential has communicated with counsel for Plaintiff and Defendant, neither of whom oppose this motion.

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Case 1:07-cv-00155-CFL

Document 12

Filed 03/15/2007

Page 2 of 2

Respectfully submitted,

/s/ David Hammond, Esq. Counsel of Record John E. McCarthy, Jr., Esq. Adelicia Cliffe Taylor Of Counsel CROWELL & MORING, LLP 1001 Pennsylvania Avenue, N.W. Washington, D.C. 20004-2595 Tel. (202) 624-2500 Fax (202) 508-8989 Counsel for Presidential Airways, Inc. Dated: March 15, 2007

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