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

Case 1:07-cv-00090-ECH

Document 9

Filed 02/14/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS Bid Protest ___________________________________ ) R&D DYNAMICS CORPORATION, ) ) Plaintiff, ) ) v. ) Court No. 07-90C ) (Judge Emily C. Hewitt) UNITED STATES OF AMERICA, ) ) Defendant. ) ____________________________________) MOTION FOR A PROTECTIVE ORDER Pursuant to Rule 26(c) of the Rules of the United States Court of Federal Claims, defendant respectfully requests 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. Defendant's counsel has contacted counsel for plaintiff and he consents to this motion. This case involves procurement matters and includes proprietary and confidential information, source selection information, and other sensitive procurement information. Thus, in the event that any party to this action finds it necessary to file protected materials with this Court, 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-00090-ECH

Document 9

Filed 02/14/2007

Page 2 of 3

Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Acting Director /s/ Donald E. Kinner DONALD E. KINNER Assistant Director /s/ Delisa M. Sánchez DELISA M. SANCHEZ Trial Attorney U.S. Department of Justice Civil Division Commercial Litigation Branch 1100 L St., N.W. ATTN: Classification Unit 8th Floor Washington, D.C. 20530 Telephone: (202) 616-0337 Facsimile: (202) 305-7643 Electronically filed, February 14, 2007 Attorneys for Defendant

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Case 1:07-cv-00090-ECH

Document 9

Filed 02/14/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 14h day of February, 2007, a copy of the foregoing "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/ Delisa M. Sánchez DELISA M. SANCHEZ