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

Case 1:04-cv-01661-EJD

Document 33

Filed 10/14/2005

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS KOLLMORGEN CORPORATION, Plaintiff, v. THE UNITED STATES OF AMERICA, Defendant, and GR DYNAMICS, LLC, Intervenor-Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 04-1661C Chief Judge Edward J. Damich

JOINT MOTION FOR ENTRY OF STIPULATED PROTECTIVE ORDER Plaintiff Kollmorgen Corporation, Defendant the United States and Intervenor-Defendfant GR Dynamics, LLC (collectively "the parties"), hereby jointly move for entry of the attached Stipulated Protective Order, executed by counsel for the parties. The attached Stipulated Protective Order is necessary in order to permit the parties to conduct discovery in an orderly fashion because documents of each of the parties containing protected and proprietary information are involved in this matter. Entry of the attached Protective Order will allow for the production of these documents, as well as the production of any protected documents produced by third parties to the litigation.

Case 1:04-cv-01661-EJD

Document 33

Filed 10/14/2005

Page 2 of 2

The parties have agreed through their counsel to entry of the attached Stipulated Protective Order, as evidenced by their counsel's signatures on the document. The parties, therefore, jointly move for entry of the attached Stipulated Protective Order. Dated: October 14, 2005 s/Andrew M. Riddles by s/Steven Pepe JOSEPH A. DEGIROLAMO ANDREW M. RIDDLES ANDREA L. WAYDA MORGAN & FINNEGAN, LLP 3 World Financial Center New York, New York 10281-2101 Telephone: (212) 415-8700 Facsimile: (212) 415-8701 Attorneys For Plaintiff Kollmorgen Corporation Dated: October 14, 2005 PETER D. KEISLER Assistant Attorney General JOHN FARGO Director s/Walter W. Brown by s/Steven Pepe WALTER W. BROWN Attorney Commercial Litigation Branch Civil Division Department of Justice Washington, D.C. 20530 Telephone: (202) 307-0341 Facsimile: (202) 307-0345 Attorney for the United States Dated: October 14, 2005 s/James E. Hopenfeld by s/Steven Pepe JAMES E. HOPENFELD ROPES & GRAY, LLP One Metro Center 7001 12th Street, N.W., Suite 900 Washington, D.C. 20005-3948 Telephone: (202) 508-4600 Facsimile: (202) 508-4650 LAURENCE S. ROGERS STEVEN PEPE ROPES & GRAY, LLP 1251 Avenue of the Americas New York, New York 10020 Telephone: (212) 596-9000 Facsimile: (212) 596-9090 Attorneys for Intervenor-Defendant GR Dynamics, LLC

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