Protective Order By Outside Counsel

Date: 2024-03-22

Summary

Document 24 in AirBoss Defense Group, LLC v. United States of America, Case No. 24-cv-00365, a bid protest in the United States Court of Federal Claims before Judge Charles F. Lettow, filed March 22, 2024. It contains three Applications for Access to Information Under Protective Order by Outside Counsel, submitted by Tara D. Hopkins, Jonathan D. Shaffer and Aaron A. Kor of Haynes and Boone, LLP, counsel for defendant-intervenor New York Embroidery Studio, Inc. Each applicant states that the relationship with the client is strictly one of legal counsel and that the applicant is not involved in competitive decision-making as discussed in U.S. Steel Corp. v. United States, 730 F.2d 1465 (Fed. Cir. 1984). Each answers NONE to the questions on other attorneys, family members and prior protective order denials, and agrees to comply with the Protective Order. The filing is 9 pages.

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Full text

Case 1:24-cv-00365-PSH Document 24 Filed 03/22/24 Page 1 of 9

IN THE UNITED STATES COURT OF FEDERAL CLAIMS
Washington, D.C.

BID PROTEST

APPLICATION FOR ACCESS TO INFORMATION UNDER
PROTECTIVE ORDER BY OUTSIDE COUNSEL

1. I, Tara D. Hopkins, hereby apply for access to protected information covered by

the Protective Order issued in connection with this proceeding.

2. I am an attorney with the law firm of Haynes and Boone, LLP and have been

retained to represent New York Embroidery Studio, Inc., a party to this protest.

3. I am a member of the bar of the United States Court of Federal Claims (the

"Court").

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
Case 1:24-cv-00365-PSH Document 24 Filed 03/22/24 Page 2 of 9

that might gain a competitive advantage from access to the material 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.

5. I 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 material 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 been found to have violated a protective order issued by any

administrative or judicial tribunal: NONE.

8. [Not applicable.]

9. 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.

10. 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.

2
Case 1:24-cv-00365-PSH Document 24 Filed 03/22/24 Page 3 of 9

***

By my signature, I certify that, to the best of my knowledge, the representations set forth

above are true and correct.

s/ Tara D. Hopkins March 22, 2024
Signature Date Executed

Tara D. Hopkins, Associate .
Typed Name and Title

703-847-6300 .
Telephone Number

703-847-6312 .
Facsimile Number

s/ Tara D. Hopkins March 22, 2024
Signature of Attorney of Record Date Executed