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

Case 1:06-cv-00282-MBH

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Filed 04/17/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

Chant Engineering Co., Inc., Plaintiff, v.

United States Of America, Defendant, Dayton T. Brown, Inc. Intervenor.

) ) ) ) ) ) ) ) ) ) )

No. 06-282C (Judge Marian Blank Horn)

APPLICATION FOR ACCESS TO MATERIALS UNDER PROTECTIVE ORDER BY OUTSIDE COUNSEL

1.

I, Marc Lamer, hereby apply for access to protected materials covered by

the Protective Order issued in connection with this proceeding. 2. a. I am an attorney with the law firm of Kostos and Lamer, P.C. and have

been retained to represent Chant Engineering Co., Inc., a party to this proceeding. 3. I am _X_/am not ____ a member of the bar of the United States Court of

Federal Claims (the ACourt@). 4. My professional relationship with the party I represent in this proceeding

and its personnel is strictly one of legal counsel. I am not involved in competitive decision-making as discussed in U.S. Steel Corp. v. United States, 730 F.2d 1465 (Fed. Cir. 1984), for or on behalf of the party I represent, any entity that is an interested party to this proceeding, or any other firm that might gain a competitive advantage from access to the material disclosed under the Protective Order. I do not provide advice or participate in any decisions of such parties in matters involving similar or corresponding

Case 1:06-cv-00282-MBH

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information about a competitor. This means that I do not, for example, provide advice

concerning or participate 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 material could provide a competitive advantage. 5. I identify here (by writing Anone@ or listing names and relevant

circumstances) those attorneys in my firm who, to the best of my knowledge, cannot make the representations set forth in the preceding paragraph: ___None______________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ 6. I identify here (by writing Anone@ or listing names, position, and

responsibilities) any member of my immediate family who is an officer or holds a management position with an interested party in the proceeding or with any other firm that might gain a competitive advantage from access to the material disclosed under the protective order: ____None_____________________________________________________________ ______________________________________________________________________ ______________________________________________________________________

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Case 1:06-cv-00282-MBH

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7.

Identify here (by writing Anone@ or identifying the name of the forum,

case number, date, and circumstances) instances in which I have been denied admission to a protective order, had admission revoked or been found to have violated a protective order issued by any administrative or judicial tribunal: ____None___________________________________________________________ ___________________________________________________________________ ___________________________________________________________________ 8. I have read the Protective Order issued by the Court in this

proceeding. I will comply in all respects with that order and will abide by its terms and conditions in handling any protected information produced in connection with the proceeding. 9. I acknowledge that a violation of the terms of the Protective Order may

result in the imposition of such sanctions as may be deemed appropriate by the Court and in possible civil and criminal liability. By my signature, I certify that, to the best of my knowledge, the representations set forth above (including any attached statements) are true and correct.

/s/ MARC LAMER_________________ Signature

04/17/06___________ Date Executed

215-545-0570_____________________ Telephone Number

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