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

Case 1:08-cv-00589-GWM

Document 13

Filed 08/26/2008

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UNITED STATES COURT OF FEDERAL CLAIMS Veterans Vocational Services ("VVS"), a Service Disabled Veteran Owned Small Business Plaintiff, v. UNITED STATES, Defendant.
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USCFC CASE NO. 08-589 C Judge George W. Miller APPLICATION FOR ACCESS TO INFORMATION UNDER PROTECTIVE ORDER BY OUTSIDE COUNSEL

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APPLICATION FOR ACCESS TO INFORMATION UNDER PROTECTIVE ORDER BY OUTSIDE COUNSEL 1. I, William L. Bruckner, hereby apply for access to protected information covered by the Protective Order issued in connection with this proceeding. 2. I, William L. Bruckner, am an attorney with the law firm of Bruckner & Walker, LLP and have been retained to represent Veterans Vocational Services, a party to this proceeding. 3. I am a member of the bar of the United States Court of Federal Claims. 4. My professional relationship with the party I represent in this proceeding and its personnel is strictly one of legal counsel. I am not involved in competitive decision making as discussed in U.S. Steel Corp. v. United States, 730 F.2d 1465 (Fed. Cir. 1984), for or on behalf of the party I represent, any entity that is an interested party to this proceeding, or any other firm that might gain a competitive advantage from access to the information disclosed under the Protective Order. I do not provide advice or participate in any decisions of such parties in matters involving similar or corresponding information about a competitor. This means that I do not, for example, provide advice concerning, or participate in decisions about, marketing or advertising strategies, product research and development, product design or competitive structuring and composition of bids, offers, or proposals with respect to which the use of protected information could provide a competitive advantage.

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Case 1:08-cv-00589-GWM

Document 13

Filed 08/26/2008

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5. I, William L. Bruckner, identify here those attorneys in my firm who, to the best of my knowledge, cannot make the representations set forth in the preceding paragraph: None. 6. I identify here any member of my immediate family who is an officer or holds a management position with an interested party in the proceeding or with any other firm that might gain a competitive advantage from access to the information disclosed under the Protective Order. None. 7. I identify here instances in which I have been denied admission to a protective order, had admission revoked, or have been found to have violated a protective order issued by any administrative or judicial tribunal: None. 8. I have read the Protective Order issued by the court in this proceeding. I will comply in all respects with that order and will abide by its terms and conditions in handling any protected information produced in connection with the proceeding. 9. I acknowledge that a violation of the terms of the Protective Order may result in the imposition of such sanctions as may be deemed appropriate by the court and in possible civil and criminal liability. I certify that, to the best of my knowledge, the representations set forth above are true and correct. Dated: August 26, 2008 Respectfully submitted, s/William L. Bruckner William L. Bruckner BRUCKNER & WALKER 4550 Kearny Villa Road, Suite 209 San Diego, CA 92123 (858) 565-8300 Telephone (858) 565-0813 Facsimile [email protected] Attorneys for Plaintiff Veterans Vocational Services.

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Case 1:08-cv-00589-GWM

Document 13

Filed 08/26/2008

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CERTIFICATE OF SERVICE

I hereby certify under penalty of perjury that on this 26th day of August, 2008, a copy of the forgoing document 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 courts system.

s/ Tiffany Adams

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