Free Motion to Seal Document - District Court of Federal Claims - federal

Case 1:96-cv-00166-EJD

Document 313

Filed 02/01/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ZOLTEK CORPORATION, a Missouri corporation, Plaintiff v. UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) ) )

Case No. 96-166 C Chief Judge Edward J. Damich

MOTION TO SUBMIT REPLY BRIEF (REVISED AND RESUMITTED) UNDER SEAL Plaintiff Zoltek Corporation ("Zoltek") respectfully moves this Court for an order directing the document entitled Zoltek's Reply Brief In Support of its Motion for Sanctions (Revised and Resubmitted Pursuant to the Court's Order of January 25, 2006), be submitted under seal. Zoltek's Reply Brief (Revised) was filed on January 31, 2006. Inadvertently, Zoltek filed the Reply Brief electronically with this Court without designating it under seal. The Reply Brief (Revised) contained a confidential exhibit of a third party which, in accordance with the Court's January 25, 2006 Order, required that the entire document be submitted under seal. Zoltek apologizes for this oversight and the inconvenience to the Court.

Case 1:96-cv-00166-EJD

Document 313

Filed 02/01/2006

Page 2 of 3

For the above stated reasons, Zoltek respectfully requests that its Reply Brief (Revised), submitted to the Court on January 31, 2006, be placed under seal.

Respectfully submitted, Dated: February 1, 2006 /s/ Dean A. Monco Dean A. Monco, Esq. John S. Mortimer, Esq. WOOD, PHILLIPS, KATZ, CLARK & MORTIMER 500 West Madison Street, Suite 3800 Chicago, Illinois 60661-2511 Tel.: (312) 876-1800 Fax: (312) 876-2020 Email: [email protected] Attorneys for Plaintiff, Zoltek Corporation

Case 1:96-cv-00166-EJD

Document 313

Filed 02/01/2006

Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on February 1, 2006 a copy of the foregoing document entitled Zoltek=s Motion to Submit Reply Brief (Revised and Resubmitted) Under Seal was filed electronically. Notice of this filing will be sent to the following party by operation of the Court's electronic filing system. Parties may access this filing through the Court's System. A copy was also sent by Federal Express, next day delivery, to: Gary L. Hausken, Esq. United States Department of Justice Commercial Litigation Branch - Civil Division 1100 L Street, N.W. Room 11114 Washington, D.C. 20005

/s/ Dean A. Monco Dean A. Monco John S. Mortimer Counsel for Plaintiff Zoltek Corporation Tel: 312-876-1800 Fax: 312-876-2020