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

Case 1:06-cv-00444-LB

Document 11

Filed 06/10/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant, ) ) and ) ) COMPUSEARCH SOFTWARE SYSTEMS, INC. ) ) Defendant-Intervenor. ) AEON NEXUS CORPORATION,

Bid Protest No. 06-444C (Judge Block)

DEFENDANT'S UNOPPOSED MOTION FOR A PROTECTIVE ORDER Pursuant to the Court's instructions during the initial telephonic status conference on June 6, 2006, and pursuant to Rules 7 and 10 and Appendix C of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully moves for a protective order in this case. The attached proposed protective order has been reviewed and agreed upon by plaintiff's counsel and intervenor's counsel, who have no objection to its filing. Certain information that may necessarily be disclosed orally or in writing during this action may be competition sensitive (e.g., source selection information), proprietary, confidential, or otherwise protectable. A protective order is needed to maintain the confidentiality of this information. Therefore, in accordance with the attached proposed protective order, we request that all further filings that include protected information be under seal in this case. The parties will, of course, be prepared to redact protected materials for public consumption in accordance with the attached proposed protective order and the Rules of this Court.

Case 1:06-cv-00444-LB

Document 11

Filed 06/10/2006

Page 2 of 3

For these reasons, we request that the Court enter the attached proposed protective order in this case. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director s/ Jeffrey S. Pease JEFFREY S. PEASE Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 307-0292 Fax: (202) 514-8624 June 10, 2006 Attorneys for Defendant

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Case 1:06-cv-00444-LB

Document 11

Filed 06/10/2006

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 10th day of June, 2006, a copy of the foregoing "DEFENDANT'S UNOPPOSED 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/ Jeffrey S. Pease