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

Case 1:06-cv-00945-FMA

Document 12

Filed 05/03/2007

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UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ ) ) ) Plaintiff, ) v. ) ) UNITED STATES, ) ) Defendant. ) _________________________________________ ) NAVAJO NATION,

No. 06-945 L Hon. Francis M. Allegra (Electronically Filed on May 3, 2007)

JOINT MOTION FOR ENTRY OF CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER Pursuant to Rule 26(c) of the Rules of the United States Court of Federal Claims ("RCFC" or "Rules"), Plaintiff, the Navajo Nation, and Defendant, the United States, jointly move for entry of the Confidentiality Agreement and Protective Order ("CAPO") submitted herewith for the Court's review. The parties have discussed the need for timely exchanges of any documents necessary to prosecute and defend this litigation. To facilitate this process, the parties have negotiated and agreed to the terms and parameters contained in the accompanying CAPO and believe that entry of the CAPO will expedite these exchanges and promote the efficient and economical resolution of this lawsuit. Accordingly, good cause exists for entry of the CAPO on the grounds that it will facilitate the efficient production of such documents by both parties under clear guidelines based on governing authorities. WHEREFORE, the parties respectfully request that the Court enter the accompanying Confidentiality Agreement and Protective Order to govern future record productions in this case.

Case 1:06-cv-00945-FMA

Document 12

Filed 05/03/2007

Page 2 of 2

Respectfully submitted this 3rd day of May, 2007.

/s/ Alan R. Taradash ALAN R. TARADASH Nordhaus Law Firm, LLP 405 Martin Luther King, Jr., Avenue, NE Albuquerque, NM 87102 Tel: (505) 243-4275 Fax: (505) 243-4464 Attorney of Record for Plaintiff

/s/ Robert W. Rodrigues ROBERT W. RODRIGUES United States Department of Justice Environment and Natural Resources Division Natural Resources Section P.O. Box 663 Washington, D.C. 20044-0663 Tel: (202) 353-8839 Fax: (202) 353-2021 Attorney of Record for Defendant

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