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

Case 1:08-cv-00340-CCM

Document 23

Filed 05/16/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS Bid Protest ____________________________________ ) DELOITTE CONSULTING, LLP, ) ) Plaintiff, ) ) v. ) Court No. 08-340C ) (Judge Christine O. C. Miller) UNITED STATES, ) ) Defendant, ) ) and ) ) BEARINGPOINT, INC., ) ) Defendant-Intervenor. ) ____________________________________) DEFENDANT'S UNOPPOSED MOTION FOR A PROTECTIVE ORDER Pursuant to Rule 26(c) of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests this Court enter the accompanying proposed protective order prohibiting the disclosure of confidential source selection matters, sensitive plans or specifications, and other proprietary information in accordance with the terms and conditions set forth in the proposed protective order. Counsel for plaintiff and defendantintervenor have reviewed the protective order and consent to this motion. This case involves procurement matters and includes proprietary and confidential information, source selection information, and other sensitive procurement information. Thus, in the event that any party to this action finds it necessary to file protected materials with this Court, we request that all filings that disclose protected materials be under seal in this case.

Case 1:08-cv-00340-CCM

Document 23

Filed 05/16/2008

Page 2 of 3

For these reasons, defendant respectfully requests that this Court issue the attached proposed protective order. Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director /s/ Patricia M. McCarthy PATRICIA M. McCARTHY Assistant Director /s/ Delisa M. Sánchez DELISA M. SANCHEZ Trial Attorney Commercial Litigation Branch Civil Division United States Department of Justice Attn: Classification Unit 1100 L Street, N.W. Washington, D.C. 20530 (202) 616-0337 Attorneys for Defendant-Appellee

Of Counsel SHERRY KINLAND KASWELL Attorney Advisor U.S. Department of the Interior 1849 C Street, N.W. MS 7308 Washington, D.C. 20240

May 16, 2008

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Case 1:08-cv-00340-CCM

Document 23

Filed 05/16/2008

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 16th day of May, 2008, a copy of the foregoing "MOTION FOR A PROTECTIVE ORDER" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

/s/ Delisa M. Sánchez DELISA M. SANCHEZ