Free Application for Access to Protected Material - District Court of Federal Claims - federal

Case 1:05-cv-00448-NBF

Document 84

Filed 07/16/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS RAYTHEON COMPANY, Plaintiff, vs. THE UNITED STATES, Defendant. Case No. 05-448C

CBS CORPORATION'S APPLICATION FOR ADMISSION TO PROTECTIVE ORDER CBS Corporation ("CBS") respectfully submits this Application for Admission to the Protective Order dated July 13, 2006, in the above-captioned case ("Protective Order"). On July 13, 2006, the Court entered a Protective Order governing the disclosure of protected documents and/or information produced by Plaintiff or Defendant during the course of litigation. On June 30, 2008, the Court entered an Order in General Electric Company v. United States, Case No. 99-172C, stating: As discussed during the June 27, 2008 status conference held in Raytheon v. United States, Case No. 05-448C, the attorneys in all of the above-captioned CAS 413 cases shall be granted, upon proper request, access to briefs, expert testimony, and expert depositions that are subject to the protective orders in all of the above-captioned cases. In this regard, outside counsel for CBS, Thomas A. Lemmer, Herbert L. Fenster and Mark J. Meagher seek admission to the Protective Order to obtain access to briefs, expert testimony and expert depositions that are subject to the Protective Order. The Protective Order states that any person, including a person who the Court directs to have

Case 1:05-cv-00448-NBF

Document 84

Filed 07/16/2008

Page 2 of 2

access to the documents and information covered by the Protective Order, to whom Confidential Information is disclosed shall execute an agreement in the form of the confidentiality agreement attached hereto as Exhibit A. Attached as Exhibit A are

executed Declarations by Thomas A. Lemmer, Herbert L. Fenster and Mark J. Meagher. Counsel for CBS is prepared to comply with the Protective Order entered in this case and respectfully requests that the Court grant the admission of Thomas A. Lemmer, Herbert L. Fenster and Mark J. Meagher to the Protective Order dated July 13, 2006. Respectfully submitted this 16th day of July, 2008.

Of Counsel: Herbert L. Fenster McKenna Long & Aldridge LLP 1900 K Street, N.W. Washington, DC 20006 Mark J. Meagher McKenna Long & Aldridge LLP 1875 Lawrence Street, Suite 200 Denver, Colorado 80202 Eric J. Sobczak CBS Corporation Law and Environmental Affairs 11 Stanwix Street Pittsburgh, PA 15222-1384
DN:32145431.1

s/Thomas A. Lemmer Thomas A. Lemmer McKenna Long & Aldridge LLP 1875 Lawrence Street, Suite 200 Denver, Colorado 80202 (303) 634-4000 FAX: (303) 634-4400 ATTORNEYS FOR CBS CORPORATION

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