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

Case 1:05-cv-00945-EGB

Document 15

Filed 07/10/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS OGDEN SUPPORT SERVICES, INC., et al., Plaintiffs, vs. UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) )

No. 05-945C (Senior Judge Bruggink)

DEFENDANT'S UNOPPOSED MOTION FOR A PROTECTIVE ORDER Pursuant to Rule 26(c) of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests that this Court enter a protective order in the form attached hereto as Exhibit A. Counsel for the parties have conferred pursuant to Rule 26(c), and plaintiffs' counsel has advised defendant's counsel that this motion will not be opposed. Defendant respectfully requests that this Court enter the attached order principally to protect against the potentially harmful disclosure of information related to the organizational operations of and employees within the Central Intelligence Agency, one of the agency's involved in this case. The necessity of protecting such information against public disclosure has been recognized by Congress, e.g., Central Intelligence Agency Act of 1949, § 6, as amended, codified at 50 U.S.C. § 403g. Accordingly, entry of the attached protective order is proper and in the public interest. For the foregoing reasons, defendant respectfully requests that this Court allow this motion and enter a protective order in the form attached hereto as Exhibit A. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

Case 1:05-cv-00945-EGB

Document 15

Filed 07/10/2006

Page 2 of 3

DAVID M. COHEN Director /s/ Bryant G. Snee BRYANT G. SNEE Assistant Director

/s/ John Warshawsky JOHN WARSHAWSKY 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) 307-0010 Facsimile: (202) 514-9163 Attorneys for Defendant July 10, 2006

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Case 1:05-cv-00945-EGB

Document 15

Filed 07/10/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on July 10, 2006, a copy of foregoing "DEFENDANT'S UNOPPOSED 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 and that parties may access this filing through the Court's system.

/s/ John Warshawsky _______________________