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

Case 1:05-cv-00595-EJD

Document 16

Filed 07/21/2006

Page 1 of 2

UNITED STATES COURT OF FEDERAL CLAIMS

) ) ) Plaintiff, ) vs. ) ) The United States of America ) Defendant. ) __________________________________________)

Northrop Grumman Information Technology, Inc.,

No. 05-595C Hon. Loren Smith, Senior Judge

MOTION FOR ENTRY OF PROTECTIVE ORDER

Plaintiff Northrop Grumman Information Technology, Inc., ("Northrop"), by and through counsel, requests the court to enter a Form 8 protective order, attached hereto, for the reasons set forth below. Defendant's counsel has no objection to this motion. As part of its discovery, defendant has requested documentation related to the employment of certain present and former Northrop employees. Northrop believes that defendant is entitled to such documents as they are relevant to the case, but that the personnel files responsive to defendant's requests necessarily contain various confidential information on the individuals and may in some cases contain proprietary business information of Northrop. Accordingly, the parties have agreed that a protective order covering the confidential information should be put in place prior to defendant's counsel's review of the files. The Form 8 protective order attached hereto will be necessary and sufficient to protect the confidentiality of the documents. The parties had previously agreed that defendant's counsel would depose one former and one present Northrop employee in California on August 1 and 2, 2006, and plaintiff's counsel has made travel arrangements to be there, however defendant's counsel

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Case 1:05-cv-00595-EJD

Document 16

Filed 07/21/2006

Page 2 of 2

will require an opportunity to review the confidential documents in order to prepare for such depositions. Plaintiff therefore requests the court to issue the protective order as soon as possible to enable the parties to proceed with discovery as planned.

Respectfully submitted, /s/ Michael E. Geltner, Esq. Michael E. Geltner, Esq. Geltner & Associates, P.C. 10 E Street, S.E. Washington, D.C. 20003 T: (202) 547-1136 F: (202) 547-1138 Attorney for Plaintiff

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the Plaintiff's Motion for Entry of a Protective Order was sent this 21st day of July, 2006 by electronic filing transmission to: J. Reid Prouty, Esq. Commercial Litigation Branch Civil Division U.S. Department of Justice Attention: Classification Unit, 8th Floor 1100 L Street, NW Washington, DC 20530

/s/ Michael E. Geltner, Esq.

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