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

Case 1:06-cv-00233-BAF

Document 142

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 MOTION TO FILE TO REPLY TO PLAINTIFFS' RESPONSE TO DEFENDANT'S CROSS-MOTION FOR SUMMARY JUDGMENT UNDER SEAL, AND REQUEST FOR EXPEDITED CONSIDERATION Defendant, the United States, respectfully requests that the Court grant allow the Government to file its reply to plaintiffs' response to our cross-motion for summary judgment under seal. The reply is likely to contain Sensitive Security Information that should be kept confidential. requests of plaintiffs. The Court has granted similar

Because our reply is due today, June 18,

2008, we respectfully request expedited consideration of this request. Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director

s/Bryant G. Snee by s/Brian M. Simkin BRYANT G. SNEE Deputy Director

Case 1:06-cv-00233-BAF

Document 142

Filed 06/18/2008

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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

2

Case 1:06-cv-00233-BAF

Document 142

Filed 06/18/2008

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CERTIFICATE OF FILING I hereby certify that on June 18, 2008, a copy of the foregoing DEFENDANT'S MOTION TO FILE TO REPLY TO PLAINTIFFS' RESPONSE TO DEFENDANT'S CROSS-MOTION FOR SUMMARY JUDGMENT UNDER SEAL, 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