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

Case 1:05-cv-01223-FMA

Document 20

Filed 03/15/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

CLEARMEADOW INVESTMENTS, LLC, CLEARMEADOW CAPITAL, TAX TAX MATTERS PARTNER Plaintiff,

v. UNITED STATES OF AMERICA, Defendant.

) ) ) ) ) ) ) ) ) ) ) )

No. 05-1223 T (Judge Allegra)

_________________________ CONSENT MOTION FOR ENTRY OF A PROTECTIVE ORDER _________________________ The defendant, the United States served a Rule 45 subpoena on Societe Generale ("SG") in the above-referenced action. In order to protect the privacy of confidential tax and financial information of individuals whose transactions are not directly in dispute in this case, and the confidentiality of proprietary and trade secret information of SG, SG and the defendant ask the Court to enter a protective order with respect to certain documents to be produced in response to that subpoena. SG and the defendant have agreed upon the terms of such a protective order, which is filed with this document as an appendix. SG has agreed that the defendant's trial attorney may submit this document with its consent.

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Case 1:05-cv-01223-FMA

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Filed 03/15/2007

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WHEREFORE SG and the defendant ask the Court to issue a protective order in the form of the attached appendix. Once the order is issued, the defendant will mail a copy to Societe Generale through its attorney. Respectfully submitted, s/ Robert Stoddart ROBERT STODDART Attorney of Record U.S. Justice Department, Tax Division Court of Federal Claims Section P.O. Box 26, Ben Franklin Station Washington, D.C. 20044 TEL: (202) 307-6445 FAX: (202) 514-9440 EILEEN J. O'CONNOR Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section s/ David Gustafson Of Counsel March 15, 2007

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Case 1:05-cv-01223-FMA

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Filed 03/15/2007

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CERTIFICATE OF SERVICE I certify that service of the foregoing document has, this 15th day of March, 2007, been made on Societe Generale's attorney by mailing a copy in a postage prepaid envelope to the following address: Marshall H. Fishman, Esquire Kramer Levin Naftalis & Frankel LLP 1177 Avenue of the Americas New York, NY 10036-2714

s/ Robert Stoddart Justice Department (Tax) Court of Federal Claims Section Post Office Box 26 Ben Franklin Post Office Washington, DC 20044 (202) 307-6440