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IN THE UNITED STATES COURT OF FEDERAL CLAIMS
BID PROTEST
AirBoss Defense Group, LLC,
Plaintiff,
v.
United States,
Defendant.
No.: 24-cv-00365
MOTION FOR A PROTECTIVE ORDER
Pursuant to Rule 5.2(e) of the Rules of the United States Court of Federal Claims, Plaintiff,
AirBoss Defense Group, LLC (“ADG”), hereby respectfully requests that the Court issue a
standard Protective Order in this matter consistent with U.S. Court of Federal Claims Form 8,
Protective Order in Procurement Protest Cases.
ADG believes that the issuance of a Protective Order is necessary to safeguard the
confidentiality of competition-sensitive or otherwise protectable information likely to be disclosed
orally or in writing during the course of this litigation.
ADG is likely to suffer serious competitive harm if such information is not adequately
safeguarded.
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Dated: March 7, 2024
Respectfully submitted,
/s/ Daniel P. Graham
Daniel P. Graham
Llewelyn M. Engel
MCDERMOTT WILL & EMERY LLP
500 North Capitol Street, N.W.
Washington, DC 20001
202-756-8890
Counsel for AirBoss Defense Group, LLC
CERTIFICATE OF SERVICE
I hereby certify that on March 7, 2024, I caused a copy of the foregoing document to be
electronically filed with the clerk using the Court’s CM/ECF system. I further certify that I have
served the foregoing document via Electronic Mail on the following:
United States Department of Justice
Commercial Litigation Branch
Civil Division, 8th Floor
1100 L Street NW
Washington, DC 20530
E-mail: nationalcourts.bidprotest@usdoj.gov
s/ Daniel P. Graham
Daniel P. Graham
MCDERMOTT WILL & EMERY LLP
500 North Capitol Street, N.W.
Washington, DC 20001
202-756-8890
Counsel for AirBoss Defense Group, LLC