Free Motion to Amend/Correct - District Court of Federal Claims - federal

Case 1:98-cv-00168-FMA

Document 320

Filed 01/12/2006

Page 1 of 4

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) NORTH STAR ALASKA HOUSING ) CORPORATION, ) ) Plaintiff, ) ) v. ) No. 98-168C ) Judge Francis M. Allegra THE UNITED STATES, ) ) Defendant. ) ____________________________________) PLAINTIFF'S UNOPPOSED MOTION FOR ENTRY OF AN AMENDMENT TO THE MARCH 31, 2005 PROTECTIVE ORDER On March 31, 2005, the Court entered a Protective Order respecting the disclosure of highly confidential and sensitive proprietary business information about the operation of North Star. Plaintiff North Star Alaska Housing Corporation ("North Star") respectfully requests that the Court enter an Amendment to the March 31, 2005 Protective Order in order to allow pleadings that contain such highly confidential and sensitive proprietary business information to be filed under seal. Plaintiff requests that the attached Amendment to the March 31, 2005 Protective Order be adopted and ordered by the Court. Counsel for Defendant has represented to counsel for Plaintiff that Defendant consents to this motion and consents to the Amendment to the March 31, 2005 Protective Order. Dated: January 12, 2006 Respectfully submitted, s/ Paul W. Killian__________________ PAUL W. KILLIAN Akin Gump Strauss Hauer & Feld LLP 1333 New Hampshire Ave., N.W. Washington, D.C. 20036 (202) 887-4000 (phone) (202) 887-4288 (fax)

Case 1:98-cv-00168-FMA

Document 320

Filed 01/12/2006

Page 2 of 4

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) NORTH STAR ALASKA HOUSING ) CORPORATION, ) ) Plaintiff, ) ) v. ) No. 98-168C ) Judge Francis M. Allegra THE UNITED STATES, ) ) Defendant. ) ____________________________________) AMENDMENT TO THE MARCH 31, 2005 PROTECTIVE ORDER 1. This Amendment is entered to supplement the March 31, 2005 Protective Order entered

by the Court in the above captioned action. The March 31, 2005 Protective Order remains in full force and effect. 2. A document containing protected information described in the Court's March 31, 2005

Protective Order may be filed electronically under seal. In addition, protected information subject to the March 31 Protective Order may be physically delivered only to the Court and to individuals authorized by this Protective Order, and must be in a sealed parcel containing the legend "PROTECTED INFORMATION ENCLOSED" conspicuously placed on the outside of the parcel containing the information. A copy of the certificate of service identifying the document being filed should be attached to the front of each parcel. (a) The first page of each document containing protected information is to be clearly marked as follows: Protected Information to be Disclosed Only in Accordance with U.S. Court of Federal Claims Protective Order. The party claiming protection must identify the specific portion of the information for which it is claiming protection.

Case 1:98-cv-00168-FMA

Document 320

Filed 01/12/2006

Page 3 of 4

(b) Any courtesy copies of protected information that are filed with the Court for use by the judge should be marked as such. (c) The Court will maintain properly marked protected pleadings or information under seal. 3. A party that files a pleading in accordance with paragraph 2 hereof shall promptly serve

on each other party a proposed redacted copy of the pleading with the claimed protected information deleted and clearly marked "Proposed Redacted Copy" in the upper-right-hand corner of the first page. (a) Within two business days after their receipt of the proposed redacted copy, other

parties shall advise the party originating the pleading of any additional redactions they require. The originating party shall promptly provide each party with a copy of the pleading from which all information that any party has requested be redacted has been redacted and clearly marked "Agreed-Upon Redacted Copy ­ May Be Made Public" in the upper right-hand corner of the page. During the two-day period, the proposed redacted copy shall be treated as protected. At the expiration of the two-day period, or when agreement is reached, the agreed-upon redacted copy shall be filed with the Court by the originating party. IT IS SO ORDERED. _________________________ Francis M. Allegra, Judge

____________________, 2006

Case 1:98-cv-00168-FMA

Document 320

Filed 01/12/2006

Page 4 of 4

CERTIFICATE OF FILING I hereby certify that a true and correct copy of the foregoing Plaintiff's Unopposed Motion for Entry of an Amendment to the March 31, 2005 Protective Order was filed electronically on this 12th day of January, 2006.

s/ Paul W. Killian _______________________ Paul W. Killian