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

Case 1:06-cv-00233-BAF

Document 134

Filed 05/09/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS FEDERAL AIR MARSHAL 1, et al., Plaintiffs, No. 06-233C vs. (Judge Futey) THE UNITED STATES, Defendant. MOTION TO FILE UNDER SEAL PLAINTIFFS' COMBINED REPLY BRIEF IN SUPPORT OF MOTION FOR PARTIAL SUMMARY JUDGMENT AND RESPONSE IN OPPOSITION TO DEFENDANT'S CROSS-MOTION FOR SUMMARY JUDGMENT, AND PLAINTIFFS' RESPONSE TO DEFENDANT'S PROPOSED FINDINGS OF FACT Plaintiffs, by their undersigned attorney, move for leave to file under seal Plaintiffs' Combined Reply Brief in Support of Motion for Partial Summary Judgment and Response in Opposition to Defendant's Cross-Motion for Summary Judgment (with appendices), and Plaintiffs' Response to Defendant's Proposed Findings of Fact (with appendices). These documents are being filed electronically at the same time as this motion. In support of this motion, plaintiffs state as follows: 1. Defendant has designated numerous depositions in this case as containing Sensitive

Security Information, which must be filed under seal. 2. 3. Plaintiffs' pleadings reference excerpts from some of these designated depositions. Counsel for defendant has requested that plaintiffs file their pleadings related to

summary judgment in this case under seal. WHEREFORE, plaintiff prays for leave to file under seal Plaintiffs' Combined Reply Brief in Support of Motion for Partial Summary Judgment and Response in Opposition to Defendant's Cross-Motion for Summary Judgment (with appendices), and Plaintiffs' Response to Defendant's

Case 1:06-cv-00233-BAF

Document 134

Filed 05/09/2008

Page 2 of 2

Proposed Findings of Fact (with appendices). Respectfully submitted,

/s/ Stephen G. Seliger One of Plaintiffs' Attorneys Stephen G. Seliger Law Offices of Stephen G. Seliger 155 North Michigan Avenue Suite 501 Chicago, Illinois 60601 (312) 616-4244 (312) 565-7289 (telefax) Of Counsel Joel M. Hellman 155 North Michigan Avenue Suite 535 Chicago, Illinois 60604 (312) 616-3436 (312) 565-7289 (telefax) James G. Bradtke Soule, Bradtke & Lambert 155 North Michigan Avenue Suite 504 Chicago, Illinois 60601 (312) 616-4422 (312) 616-4423 (telefax)