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

Case 1:06-cv-00425-NBF

Document 11

Filed 06/05/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS INTERSPIRO, INC., Plaintiff, v. THE UNITED STATES, Defendant. and, MINE SAFETY APPLIANCES CO., Defendant-Intervenor. ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 06-425C (Judge Firestone)

DEFENDANT'S UNOPPOSED MOTION FOR A PROTECTIVE ORDER 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. Plaintiff's counsel and intervenor's counsel have been contacted and do not oppose this motion. Certain documents that will be included in the administrative record in this case contain confidential, proprietary, or otherwise sensitive information. A protective order is needed to maintain the confidentiality of this material. Therefore, we request that all further filings be under seal in this case. We will, of course, be prepared to redact protected materials for public consumption in accordance with the Rules of this Court.

Case 1:06-cv-00425-NBF

Document 11

Filed 06/05/2006

Page 2 of 2

For these reasons, we request that the Court enter the attached protective order in this case. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Brian M. Simkin BRIAN M. SIMKIN Assistant Director s/ Doris S. Finnerman DORIS S. FINNERMAN 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) 307-0300 Fax: (202) 305-7643 Attorneys for Defendant June 5, 2006