Free Notice (Other) - District Court of Federal Claims - federal

Case 1:06-cv-00425-NBF

Document 90

Filed 09/15/2006

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Electronically Filed on September 15, 2006 IN THE UNITED STATES COURT OF FEDERAL CLAIMS Bid Protest INTERSPIRO, INC., Plaintiff, and SCOTT TECHNOLOGIES, INC., d/b/a SCOTT HEALTH & SAFETY, Plaintiff, v. UNITED STATES, Defendant, and MINE SAFETY APPLIANCES CO., Defendant-Intervenor. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 06-425C; No. 06-443C Judge Firestone CONSOLIDATED

DEFENDANT-INTERVENOR MINE SAFETY APPLIANCES COMPANY'S NOTICE OF OBJECTION TO THE APPLICATION FOR ACCESS TO PROTECTED MATERIAL FOR RICHARD P. BRESS SUBMITTED BY INTERSPIRO, INC. Pursuant to the Paragraph 2(b) of the Protective Order entered in this case, Defendant-Intervenor, Mine Safety Appliance Company ("MSA") respectfully notifies the Court of its objection to the September 14, 2006 Application for Access to Protected Material for Richard P. Bress submitted by Interspiro, Inc. Interspiro submitted Mr. Bress' application to the other parties for the first time on September 14, 2006, after judgment was entered in this case on September 13, 2006. Because this case is over, there is no need for anyone else to have access

Case 1:06-cv-00425-NBF

Document 90

Filed 09/15/2006

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to protected information. Providing access to yet another person can only increase the risk of inadvertent disclosure of protected information. Already, Interspiro has 8 representatives (7 attorneys and 1 consultant) who have been admitted access to protected information. Interspiro offered no reason or need for further admissions, and did not respond to MSA's request for such justification. For the foregoing reasons, MSA respectfully objects to the Application for Access to Protected Material for Richard P. Bress submitted by Interspiro. Respectfully Submitted, s/ Thomas P. Humphrey, Esq. Counsel of Record Elizabeth W. Newsom, Esq. Amy E. Laderberg, Esq. Rebecca K. Lee, Esq. Brian T. McLaughlin CROWELL & MORING, LLP 1001 Pennsylvania Avenue, N.W. Washington, D.C. 20004-2595 Tel. (202) 624-2500 Fax (202) 628-5116 September 15, 2006 Counsel for Mine Safety Appliances Company

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Case 1:06-cv-00425-NBF

Document 90

Filed 09/15/2006

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CERTIFICATE OF FILING I hereby certify that on the 15th day of September, 2006, the foregoing DEFENDANT-INTERVENOR MINE SAFETY APPLIANCES COMPANY'S NOTICE OF OBJECTION TO THE APPLICATION FOR ACCESS TO PROTECTED MATERIAL FOR RICHARD P. BRESS SUBMITTED BY INTERSPIRO, INC. was filed electronically. This filing will be available to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

s/ Thomas P. Humphrey