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

Case 1:07-cv-00582-JFM

Document 7

Filed 08/20/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS Bid Protest INFRASTRUCTURE DEFENSE TECHNOLOGIES, LLC Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-582 (Senior Judge Merow)

DEFENDANT'S MOTION FOR A PROTECTIVE ORDER Pursuant to Rule 7(b) of the Rules of the Court of Federal Claims, defendant, the United States, respectfully moves for the entry of a protective order in this action. Defendant has unsuccessfully attempted to reach counsel for plaintiff, Infrastructure Defense Technologies, LLP, to ascertain whether plaintiff will oppose this motion. On August 9, 2007, the Court ordered the United States to filed the administrative record filed on or before August 20, 2007. Various documents that the United States will include in the administrative record contain confidential, proprietary or otherwise sensitive information. A protective order is needed to maintain the confidentiality of this material. The United States has attached a proposed protective order as Exhibit A to this motion. For these reasons, the United States respectfully requests that the Court grant this unopposed motion for a protective order. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

Case 1:07-cv-00582-JFM

Document 7

Filed 08/20/2007

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/s Brian M. Simkin BRIAN M. SIMKIN Assistant Director s/ David A. Harrington DAVID A. HARRINGTON Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 (202) 307-0277 Attorneys for Defendant Dated: August 20, 2007

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Case 1:07-cv-00582-JFM

Document 7

Filed 08/20/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on the 20th day of August 2007, a copy of "DEFENDANT'S UNOPPOSED 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/ David A. Harrington