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

Case 1:08-cv-00500-LAS

Document 9

Filed 07/14/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS PRECISION LIFT, INC., Plaintiff, v. ) ) ) ) ) ) ) ) ) )

No. 08-500 C (bid protest) (Senior Judge Smith)

THE UNITED STATES, Defendant.

DEFENDANT'S UNOPPOSED MOTION FOR PROTECTIVE ORDER With the consent of plaintiff, we respectfully request that the Court issue its standard protective order in this case. The administrative record that is being prepared for this case includes proprietary and competition-sensitive information, the public release of which potentially would prejudice the Government and those parties that bid upon the contract that is the subject of this protest. Accordingly, we respectfully request that the Court issue a protective order. A proposed protective order, taken from the forms following the Court's rules and modified to include the proper caption, is attached. Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director

s/ Brian M. Simkin Brian M. Simkin Assistant Director

Case 1:08-cv-00500-LAS

Document 9

Filed 07/14/2008

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s/ Scott T. Palmer Scott T. Palmer Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 307-6299 Fax: (202) 305-1571

Dated: July 14, 2008

Attorneys for Defendant

Attachment: Draft Protective Order

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Case 1:08-cv-00500-LAS

Document 9

Filed 07/14/2008

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 14th day of July 2008, a copy of the foregoing "DEFENDANT'S MOTION FOR 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/ Scott T. Palmer

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