Free Application for Access to Protected Material - District Court of Federal Claims - federal

Case 1:06-cv-00425-NBF

Document 18

Filed 06/08/2006

Page 1 of 13

APPLICATION FOR ACCESS TO iNFORMATION UNDER PROTECTIVE ORDER BY EXPERT CONSULTANT OR WITNESS

~niteb ~tate~ Qtourt of Jeb~raL Q~Laim~
) ) Plaintiff,
v.

Iriterspiro.

Inc

)

No.

06-

425C

THE UNITED

STATES,
Defendant.

) ) ) ) )

Judge

Firestone

APPLICATION FOR ACCESS TO INFORMATION UNDER
PROTECTIVE ORDER BY EXPERT CONSULTANT OR WITNESS
I.

apply

with self-employed and hereby I, the undersigned, am a consultant for access to protected information covered by the Protective Order issued in connection with this

proceeding.
2. have been retained
David
IL

by

Interspi.ro,

tflC.

klazelton

,assistintherepresentationof

and will, under the direction and control Interopiro. Inc. inihis

proceeding. 3. 1 hereby certify that I am not involved in competitive decision making as discussed in U.S. Steel Corp. v. Uni~ed States, 730 F.2d 1465 (Fed. Cir. 1984), for or on behalf of any party to this proceeding or any other firm that might gain a competitive advantage from access to the information disclosed under the protective order. Neither I nor my employer provides advice or participates in any decisions of such parties in matters involving similar or corresponding information about a competitor, This means, for example, that neither I nor my employer provides advice concerning, or participates in decisions about, marketing or advertising strategies, product research and development, product design or competitive structuring and composition of bids, offers, or proposals with respect to which the use of protected information could provide a competitive advance. 4. My professional relationship with the party for whom I am retained in this proceeding and its personnel is strictly as a consultant on issues relevant to the proceeding. Neither I nor any member of my immediate family holds office or a management position in any company that is a party in this proceeding or in any competitor or potential competitor of a party.
5. J have attached the
a.
a a

following

information:

current resume

b.

my education and employment experience to date; list of all clients for whom have performed work within the two years prior to the date of

describing
a

this
c, a

application

and

brief description of the work
am

statement of the

services I

expected

to
or

performed; perform in connection

with this

description of the

financial interests that 1,

any member of my immediate

proceeding; a family, has in any

Case 1:06-cv-00425-NBF

Document 18

Filed 06/08/2006

Page 8 of 13

ATTACHMENT
For the avoidance of doubt, I
am

5(
consultant in this matter in my behalf of my employer.

participating

as a

individual

capacity,

as an

independent

contractor, and not

on

My current employer, MacAuley Brown, Inc. is a support contractor to the Department of Defense with offices in over 21 locations worldwide. The companys work includes Operations Research, Systems Engineering, Sofiware Development, test and Evaluation, Information Technology, and Acquisition Management Support.
To my knowledge, the company has no clients for whom it has performed work over the past two years for whom the material that is subject of this protest and would be produced under the protective order could provide a competitive advantage.

Case 1:06-cv-00425-NBF

Document 18

Filed 06/08/2006

Page 11 of 13

ATTACHMENT 5(1
None.