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

Case 1:06-cv-00377-GWM

Document 22

Filed 06/04/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

ROME RESEARCH CORPORATION, Plaintiff, Case No. 1:06-cv-377 v. UNITED STATES, Defendant Judge George W. Miller

AGREED MOTION FOR ENTRY OF PROTECTIVE ORDER AND TO GRANT APPLICATIONS FOR ACCESS TO PROTECTED INFORMATION Plaintiff Rome Research Corporation ("RRC"), with the agreement of the Defendant, United States (the "Government"), respectfully requests that the Court enter a protective order in this action to facilitate the exchange of documents, witness testimony and information in other forms. In particular, information may be disclosed orally or in writing during this action that could be competition sensitive (e.g., source selection information), proprietary, confidential, or otherwise protectable. To address these concerns, RRC, with the agreement of the Government, request that an order be entered directing that protected information, provided formally or informally during the course of this action, shall be disclosed by the parties only in accordance with the Protective Order attached hereto as Exhibit A. RRC further requests that the Court grant the applications of Daniel Abrahams and Howard Wolf-Rodda, respectively attached hereto as Exhibits B and C, for access to protected information. Mr. Abrahams and Mr. Wolf-Rodda are counsel representing RRC, and each have

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Case 1:06-cv-00377-GWM

Document 22

Filed 06/04/2007

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certified their representations concerning their eligibility for access to protected information in their applications. See Exhibits B & C. CONCLUSION For the foregoing reasons, RRC, with the Agreement of the Government, respectfully requests that the Court enter the Protective Order attached to this motion and that it further grant the applications of Daniel Abrahams and Howard Wolf-Rodda for access to protected information.

Respectfully submitted,

s/ DANIEL B. ABRAHAMS Epstein Becker & Green, P.C. 1227 25th Street, N.W., Suite 600 Washington, D.C. 20037 Tel: (202) 861-1854 Dated: June 4, 2007

CERTIFICATE OF SERVICE I hereby certify under penalty of perjury that on this 4th day of June, 2007, a copy of the foregoing "Motion for Entry of Protective Order and to Grant Applications for Access to Protected Information" 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/ ____________ Daniel B. Abrahams

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