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

Case 1:99-cv-00172-NBF

Document 360

Filed 07/07/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ______________________________________ ) GENERAL ELECTRIC COMPANY, ) ) Plaintiff, ) ) v. ) No. 99-172C ) Judge Nancy B. Firestone UNITED STATES OF AMERICA, ) ) Defendant. ) ______________________________________ ) UNISYS CORPORATION'S APPLICATION FOR ADMISSION TO PROTECTIVE ORDER Unisys Corporation ("Unisys") respectfully submits this Application for Admission to the Protective Order dated May 31, 2000 in the above-captioned case. On May 31, 2000, 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 the above-captioned case 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 abovecaptioned cases. In this regard, outside counsel for Unisys, Terry L. Albertson and Amy L. O'Sullivan, seek admission to the Protective Order to obtain access to briefs, expert testimony and expert

Case 1:99-cv-00172-NBF

Document 360

Filed 07/07/2008

Page 2 of 3

depositions that are subject to the Protective Order. The Protective Order states that any person, including a person who the Court directs to have 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 Terry L. Albertson and Amy L. O'Sullivan. Counsel for Unisys is prepared to comply with the Protective Order entered in this case and respectfully requests that the Court grant the admission of Terry L. Albertson and Amy L. O'Sulliavan to the Protective Order dated May 31, 2000. Respectfully submitted, Date: July 7, 2008 _____s/Terry L. Albertson________________ Terry L. Albertson Crowell & Moring LLP 1001 Pennsylvania Avenue, NW Washington, DC 20004 Telephone: (202) 624-2635 Facsimile: (202) 628-5116 [email protected] Attorney for Unisys Corporation Of Counsel: Amy L. O'Sullivan

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Case 1:99-cv-00172-NBF

Document 360

Filed 07/07/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 7th day of July 2008, a true and correct copy of the foregoing was sent by electronic mail and first class mail to: C. Coleman Bird U. S. Department of Justice Civil Division, Commercial Litigation Branch 1100 L Street, NW 8th Floor Washington, DC 20530 Richard Bernstein Willkie, Farr & Gallagher, LLP 1875 K Street, NW Washington, DC 20006

__________s/Terry L. Albertson_______________ Terry L. Albertson

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