Free Motion to Seal Document - District Court of Federal Claims - federal

Case 1:06-cv-00233-BAF

Document 145

Filed 06/18/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS FEDERAL AIR MARSHALS (FAM) 1, ET AL., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 06-233C (Judge Futey)

DEFENDANT'S CONSENT MOTION TO SEAL DEFENDANT'S REPLY TO PLAINTIFFS' RESPONSE TO DEFENDANT'S CROSS-MOTION FOR SUMMARY JUDGMENT, AND REQUEST FOR EXPEDITED CONSIDERATION Defendant, the United States, respectfully requests that the Court immediately seal Documents 144 and 144-2, Defendant's Reply To Plaintiffs' Response To Defendant's Cross-Motion For Summary Judgment and its appendix. Those documents contain Sensitive Despite

Security Information that should be kept confidential.

obtaining leave from the Court to file those documents under seal, and labeling them as filed under seal, lead counsel for defendant inadvertently filed those documents in the open, at 5:31 P.M. EDT, today, June 18, 2008. We regret this error.

Counsel for plaintiffs has represented to counsel for defendant that plaintiffs consent to this request. Because

Sensitive Security Information is currently open to public view, we respectfully request expedited consideration of this request.

Case 1:06-cv-00233-BAF

Document 145

Filed 06/18/2008

Page 2 of 3

Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/Bryant G. Snee by s/Donald E. Kinner BRYANT G. SNEE Deputy Director s/Timothy P. McIlmail TIMOTHY P. MCILMAIL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Telephone: (202) 616-0342 Facsimile: (202) 514-7965 OF COUNSEL: JANESSA GRADY FLEMING Senior Counsel, Litigation Office of the Chief Counsel Transportation Security Administration Arlington, VA June 18, 2008 Attorneys for Defendant

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Case 1:06-cv-00233-BAF

Document 145

Filed 06/18/2008

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on June 18, 2008, a copy of the foregoing DEFENDANT'S CONSENT MOTION TO SEAL DEFENDANT'S REPLY TO PLAINTIFFS' RESPONSE TO DEFENDANT'S CROSS-MOTION FOR SUMMARY JUDGMENT, AND REQUEST FOR EXPEDITED CONSIDERATION 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. system. s/Timothy P. McIlmail Parties may access this filing through the Court's