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

Case 1:05-cv-00142-NBF

Document 82

Filed 01/17/2007

Page 1 of 1

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ARTURO MORENO, JR., et al., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-142C (Judge Firestone)

PLAINTIFFS' MOTION TO ADOPT PROTECTIVE ORDER The Defendant has taken the position that 1500 pages of e-mail correspondence with employees regarding the payment of overtime for a 6th day of training at the Federal Law Enforcement Employee Training Center contain information protected under the Privacy Act. The Defendant claims that redacting the information protected by the Privacy Act would be unduly burdensome. As an alternative, it has offered to produce the e-mails if the Court enters the protective order attached as Exhibit A. Both Parties have reviewed and consent to the order. In an effort to obtain the documents with the least delay and expense, the Plaintiffs respectfully request that the Court adopt the protective order in this case.

Dated: January 17, 2006

/s Michael J.D. Sweeney Getman Law Office 9 Paradies Lane New Paltz, NY 12561 (845) 255-9370 facsimile (845) 255-8649