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

Case 1:06-cv-00305-MBH

Document 41

Filed 08/22/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. & SUBSIDIARIES, Plaintiff, v. THE UNITED STATES, Defendant.

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No. 06-305 T Judge Marian Blank Horn

UNITED STATES' UNOPPOSED MOTION FOR ENTRY OF ORDER APPROVING NON-PARTY PROPOSED PROTECTIVE ORDER The United States submits this unopposed motion requesting the entry of an order adopting and approving a proposed Non-Party Agreed Protective Order, a copy of which is annexed hereto as Exhibit A. The entry of a protective order is requested by third party Chase Equipment Leasing, Inc. (f.k.a. Banc One Leasing Corp.) pursuant to subpoena duces tecum prepared by the United States. Plaintiff Consolidated Edison of New York, Inc., Defendant United States and third party Chase Equipment Leasing, Inc. have agreed to terms, subject to the Court's approval.

Case 1:06-cv-00305-MBH

Document 41

Filed 08/22/2007

Page 2 of 2

WHEREFORE the United States requests that this Court issue an Order adopting and approving the Non-party Agreed Protective Order annexed as Exhibit A. Dated: August 22, 2007

Respectfully submitted, s/ David N. Geier DAVID N. GEIER Attorney of Record U.S. Department of Justice, Tax Division Post Office Box 26 Ben Franklin Station Washington, D.C. 20044 Telephone: (202) 616-3448 Facsimile: (202) 307-0054 RICHARD T. MORRISON Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section STEVEN I. FRAHM Assistant Chief, Court of Federal Claims Section JOSEPH A. SERGI JAMES E. WEAVER ADAM R. SMART Trial Attorneys s/ Steven I. Frahm Of Counsel

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