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

Case 1:05-cv-00575-TCW

Document 28

Filed 04/26/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS PHILLIP J. LAVEZZO d/b/a DKO TECHNOLOGIES, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-575C (Judge Wheeler)

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 respectfully requests this Court enter a protective order prohibiting the disclosure of information protected by the Privacy Act, as well as information that may otherwise be secret, confidential, or otherwise proprietary, in accordance with the terms and conditions set forth in the proposed protective order. Counsel for plaintiff has reviewed the proposed protective order and consents to the entry of this protective order. Entry of a protective order is requested as discovery propounded by plaintiff requests personnel records of a former Government employee and documents prepared as part of an Inspector General investigation. For the foregoing reasons, defendant respectfully requests that this Court issue the proposed protective order. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

DAVID M. COHEN Director

Case 1:05-cv-00575-TCW

Document 28

Filed 04/26/2006

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s/ Franklin E. White Jr. FRANKLIN E. WHITE, JR. Assistant Director

s/ David D'Alessandris DAVID D'ALESSANDRIS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20005 (202) 307-1011 Attorneys for Defendant April 26, 2006

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Case 1:05-cv-00575-TCW

Document 28

Filed 04/26/2006

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on April 26, 2006, a copy of the forgoing "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. Parties may access this filing through the Court's system.

s/ David D'Alessandris