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

Case 1:05-cv-00604-MBH

Document 25

Filed 12/07/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

SCOTT TIMBER CO., Plaintiff, v. THE UNITED STATES, Defendant.

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No. 05-604C (Judge Horn)

UNOPPOSED MOTION FOR PROTECTIVE ORDER Pursuant to Rule 26(c) of the Rules of the United States Court of Federal Claims ("RCFC"), plaintiff Scott Timber Company ("Scott") hereby requests that this Court issue the attached proposed protective order in the above-captioned action. Scott has contacted defendant's counsel regarding this motion, and defendant does not oppose it.

In an effort to facilitate a compromise settlement of this case, Scott intends to provide certain information and documents concerning its damages to defendant in this action as soon as possible. Because this information and these documents include competitively sensitive information relating to Scott's business activities, this information is highly confidential and proprietary. Scott, therefore, requests that a protective order be issued to protect Scott from the harm which would occur if this confidential and proprietary information and these documents were released without restriction.

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Case 1:05-cv-00604-MBH

Document 25

Filed 12/07/2005

Page 2 of 2

For the reasons set forth above, Scott respectfully requests that the Court grant this motion.

Respectfully submitted, s/Gary G. Stevens SALTMAN & STEVENS, P.C. 1801 K Street, N.W. Suite M-110 Washington, D.C. 20006 (202) 452-2140 Counsel for Plaintiff OF COUNSEL: Alan I. Saltman SALTMAN & STEVENS, P.C. 1801 K Street, N.W. Suite M-110 Washington, D.C. 20006 (202) 452-2140 Dated: December 7, 2005

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