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

Case 1:07-cv-00073-FMA

Document 12

Filed 02/02/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ARINC ENGINEERING SERVICES, LLC Plaintiff, v. UNITED STATES, Defendant, and BAE SYSTEMS ANALYTICAL SOLUTIONS, INC. Defendant-Intervenor. ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 07-73C (Judge Allegra)

UNOPPOSED MOTION FOR PROTECTIVE ORDER The plaintiff respectfully moves this court for entry of a protective order to cover certain information that may necessarily be disclosed orally or in writing during this action. The plaintiff submits with this motion a proposed protective order that all the parties have found to be acceptable. The proposed protective order submitted with this motion is identical to the Court's protective order and applications for admission to the protective order found in this Court's Rules, Appendix of Forms, Forms 8, 9, and 10, with the exception of the addition of paragraph 1(c), which includes, within the definition of protected information, information and filings in GAO Case No. B-298893 marked as protected under the protective order issued by the GAO in that case. The plaintiff is authorized to say that counsel for the defendant and counsel for the intervenor do not oppose the entry of this order.

Respectfully submitted,

Case 1:07-cv-00073-FMA

Document 12

Filed 02/02/2007

Page 2 of 2

/s/ William T. Welch BARTON, BAKER, McMAHON & TOLLE, LLP 1320 Old Chain Bridge Road, Suite 440 McLean, Virginia 22101 (703) 448-1810 (ex. 22) - Telephone (703) 448-3336 - Facsimile Attorney of Record Counsel for ARINC Engineering Services, LLC Of Counsel: J. Patrick McMahon BARTON, BAKER, McMAHON & TOLLE, LLP 1320 Old Chain Bridge Road, Suite 440 McLean, Virginia 22101 (703) 448-1810 - Telephone (703) 448-3336 - Facsimile Dated: February 2, 2007