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

Case 1:06-cv-00146-TCW

Document 11

Filed 12/22/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TETRA TECH EC, INC. Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-146C (Judge Wheeler)

JOINT MOTION FOR A PROTECTIVE ORDER Pursuant to Rule 26(c) of the Rules of the United States Court of Federal Claims, the parties respectfully request that the Court enter the accompanying proposed protective order prohibiting the disclosure of contract proposals by third parties, evaluations of those proposals that contain confidential business information, salary information for employees of plaintiff, and other proprietary information in accordance with the terms and conditions set forth in the proposed protective order. This case involves competitive procurement matters and includes proprietary and confidential pricing information, source selection information, and other sensitive procurement information. Because similar confidentiality issues arise in bid protest cases, the proposed protective order is based upon Form No. 8 in the appendix to the Rules of the Court of Federal Claims. For the foregoing reasons, the parties request that the Court issue the attached proposed protective order.

Case 1:06-cv-00146-TCW

Document 11

Filed 12/22/2006

Page 2 of 3

Respectfully submitted, s/ William W. Thompson, Jr. William W. Thompson, Jr. Robert D. Banfield PECKAR, ABRAMSON , BASTIANELLI & KELLEY , LLP 1133 21st Street, N.W;, Suite 500 Washington, D.C. 20036 (202) 293-8815 Telephone (202) 293-7794 Facsimile Attorneys for Tetra Tech EC, Inc. s/ Roger A. Hipp ROGER A. HIPP Trial Attorney U.S. Department of Justice Civil Division Commercial Litigation Branch 1100 L St., N.W. ATTN: Classification Unit 8th Floor Washington, D.C. 20530 Telephone: (202) 305-3091 Facsimile: (202) 307-0972 December 22, 2006 Attorneys for Defendant PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director

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Case 1:06-cv-00146-TCW

Document 11

Filed 12/22/2006

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 22nd day of December, 2006, a copy of the foregoing "JOINT MOTION FOR A PROTECTIVE ORDER" 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. Parties may access this filing through the Court's system.

s/ Roger A. Hipp ROGER A. HIPP