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

Case 1:07-cv-00806-TCW

Document 13

Filed 11/23/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST THE PROTECTIVE GROUP, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-806C (Judge Wheeler)

DEFENDANT'S MOTION FOR A PROTECTIVE ORDER Defendant, the United States, respectfully requests that the Court issue a protective order, and accompanying applications for access to protective material, in this case. The Government has

collected the Notices of Intent that were discussed at the hearing held on November 19, 2007, and has determined that those notices contain proprietary information that should be protected to preserve the integrity of the current, pending procurement process. We attach a proposed protective order and proposed

applications for access to protective material that conform to the samples found at Appendix of Forms, Forms 8 to 10 of the Rules of the United States Court of Federal Claims. Counsel for plaintiff has represented to counsel for defendant that plaintiff consents to this request.

Case 1:07-cv-00806-TCW

Document 13

Filed 11/23/2007

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Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director

s/Deborah A. Bynum by s/Reginald T. Blades, Jr. DEBORAH A. BYNUM Assistant Director

s/Timothy P. McIlmail TIMOTHY P. MCILMAIL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Washington, D.C. 20530 Telephone: (202) 616-0342 Facsimile: (202) 514-7965 November 23, 2007 Attorneys for Defendant

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Case 1:07-cv-00806-TCW

Document 13

Filed 11/23/2007

Page 3 of 3

Certificate of Filing I hereby certify that on November 23, 2007, a copy of the foregoing Defendant's 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. system. Parties may access this filing through the Court's

s/Timothy P. McIlmail