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

Case 1:05-cv-00114-EJD

Document 17

Filed 12/22/2005

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS A.A.B JOINT VENTURE, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

Nos. 04-1719C, 04-1792C, 05-114C (Chief Judge Damich)

JOINT MOTION FOR ISSUANCE OF AN ORDER GOVERNING INADVERTENT DISCLOSURE OF DOCUMENTS DURING DISCOVERY Plaintiff and defendant respectfully request that the Court enter the attached consent order setting forth the procedures governing the inadvertent disclosure of documents during discovery. Because of the large volume of documents that the parties may produce during discovery in these cases, the parties may inadvertently or mistakenly produce documents that could have been withheld in whole or in part upon the basis of privilege or some other protection. The attached order specifies the procedures to be utilized by the parties in the event of an inadvertent disclosure of documents. Both parties have consented to the terms of the agreement. For these reasons, the parties respectfully requests that the Court grant their motion for issuance of an order governing inadvertent disclosure of documents during discovery.

Case 1:05-cv-00114-EJD

Document 17

Filed 12/22/2005

Page 2 of 2

Respectfully submitted,

Bell, Boyd & Lloyd PLLC s/ Brian Cohen _________________________ Brian Cohen, Esq. Bell, Boyd & Lloyd PLLC 1615 L Street, N.W. Suite 1200 Washington, DC (202) 955-6823 (phone) (202) 835-4130 (fax) Attorney for Plaintiff Dated: December 22, 2005

PETER D. KEISLER Assistant Attorney General s/ David M. Cohen _________________________ DAVID M. COHEN Director s/ Shalom Brilliant ________________________ SHALOM BRILLIANT Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit Room 8012 Washington, D.C. 20530 Telephone: (202) 305-7561 Facsimile: (202) 305-7643 Attorneys for Defendant Dated: December 22, 2005

Filed Electronically With the consent of the Attorney for Plaintiff

2