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

Case 1:05-cv-00490-TCW

Document 22

Filed 04/03/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS SSA MARINE, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-490C (Chief Judge Damich)

JOINT MOTION FOR ENTRY OF PROTECTIVE ORDER AND FOR EXPEDITED CONSIDERATION Pursuant to Rule 26(c) of the Rules of the United States Court of Federal Claims, the parties respectfully request the Court enter a protective order relating to the disclosure of secret, confidential, and other proprietary information in accordance with the terms and conditions set forth in the attached proposed protective order. The parties request expedited consideration because the protective order will allow the Government's expert consultants access to plaintiff's documents that contain confidential information, and it is important for the Government's experts to gain access to this information as soon as possible so that they can perform the analysis for which they were retained. For the foregoing reasons, the parties respectfully request that the Court grant this motion and issue the proposed protective order. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

Case 1:05-cv-00490-TCW

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Filed 04/03/2006

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DAVID M. COHEN Director /s Bryant G. Snee BRYANT G. SNEE Assistant Director /s John Butler JOHN BUTLER SHER & BLACKWELL 1850 M Street, N.W., Ste. 900 Washington, DC 20036 Tele: (202) 463-2510 Fax: (202) 463-4950 Attorneys for Plaintiff /s Thomas D. Dinackus THOMAS D. DINACKUS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, DC 20530 Tele: (202) 307-6289 Fax: (202) 514-7969 Attorneys for Defendant DATED: April 3, 2006 DATED: April 3, 2006

OF COUNSEL: HEATHER M. SPRING Sher & Blackwell

OF COUNSEL: JOHN B. ALUMBAUGH PETER E. YOUNG U.S. Agency for International Development

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Case 1:05-cv-00490-TCW

Document 22

Filed 04/03/2006

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NOTICE OF FILING I hereby certify that on April 3, 2006, a copy of the foregoing "JOINT MOTION FOR ENTRY OF PROTECTIVE ORDER AND FOR EXPEDITED CONSIDERATION" 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. access this filing through the Court's system. /s Thomas D. Dinackus Parties may