Free Motion to Amend/Correct - District Court of Federal Claims - federal

Case 1:02-cv-00466-LB

Document 50

Filed 01/23/2004

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THE UNITED STATES COURT OF FEDERAL CLAIMS SUNOCO, INC., and PUERTO RICO SUN OIL COMPANY, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 02-466C (Chief Judge Damich)

PLAINTIFF'S MOTION TO AMEND PARAGRAPH 12 OF THE PROTECTIVE ORDER Plaintiffs Sunoco, Inc. and Puerto Rico Sun Oil Company ("Sunoco") hereby move to amend paragraph 12 of the protective order entered in this action on January 9, 2004. Paragraph 12 provides that confidential material retained by the Court will lose its confidential status after five years has elapsed from the entry of a final judgment. Sunoco respectfully submits that there may be some highly-sensitive materials submitted to the Court as to which Sunoco would want to seek additional protection after the entry of final judgment. Therefore, Sunoco proposes that paragraph 12 be amended to provide that, within 60 days after the entry of a final judgment, any party owning confidential material may file a motion seeking to extend the time in which the material will be treated as confidential under the terms of the protective order or seeking to withdraw the material from the record. Counsel for the defendant has informed the undersigned that the defendant does not oppose this motion.

Case 1:02-cv-00466-LB

Document 50

Filed 01/23/2004

Page 2 of 2

Respectfully submitted, /s J. Keith Burt J. Keith Burt Mayer, Brown, Rowe & Maw 1909 K Street, N.W. Washington, D.C. 20006 (202) 263-3208 (Phone) (202) 263-5308 (Fax) Attorneys for Sunoco, Inc. and Puerto Rico Sun Oil Company Of Counsel: Gary A. Winters Mayer, Brown, Rowe & Maw 1909 K Street, N.W. Washington, DC 20006

January 23, 2004

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