Full text
1
United States Court of Federal Claims
AIRBOSS DEFENSE GROUP, LLC,
)
)
Plaintiff,
)
)
No. 24-365
v.
)
)
Judge Charles F. Lettow
UNITED STATES,
)
)
Defendant.
)
APPLICATION FOR ACCESS TO INFORMATION UNDER
PROTECTIVE ORDER BY OUTSIDE COUNSEL
1.
I, Eric S. Crusius, 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 Holland & Knight LLP and have been
retained to represent String King Lacrosse LLC, a party to this proceeding.
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
that might gain a competitive advantage from access to the information 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 (by writing “none” or listing names and relevant circumstances)
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 (by writing “none” or listing names, position, and responsibilities)
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 information disclosed under the Protective Order: None
Case 1:24-cv-00365-PSH Document 32 Filed 04/15/24 Page 1 of 6
2
7.
I identify here (by writing “none” or identifying the name of the forum, case
number, date, and circumstances) instances in which I have been denied admission to a
protective order, had admission revoked, or have 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.
***
By my signature, I certify that, to the best of my knowledge, the representations set forth
above (including attached statements) are true and correct.
15 April 2024
Eric S. Crusius, Partner
Date Executed
Attorney of Record for
String King Lacrosse LLC
HOLLAND & KNIGHT LLP
1650 Tysons Boulevard – Suite 1700
Tysons, Virginia 22102
Telephone: (703) 720-8042
Facsimile: (703) 720-8610
Eric.Crusius@hklaw.com
#501456219_v1
Case 1:24-cv-00365-PSH Document 32 Filed 04/15/24 Page 2 of 6
1
United States Court of Federal Claims
AIRBOSS DEFENSE GROUP, LLC,
)
)
Plaintiff,
)
)
No. 24-365
v.
)
)
Judge Charles F. Lettow
UNITED STATES,
)
)
Defendant.
)
APPLICATION FOR ACCESS TO INFORMATION UNDER
PROTECTIVE ORDER BY OUTSIDE COUNSEL
1.
I, Amy L. Fuentes, 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 Holland & Knight LLP and have been
retained to represent String King Lacrosse LLC, a party to this proceeding.
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
that might gain a competitive advantage from access to the information 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 (by writing “none” or listing names and relevant circumstances)
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 (by writing “none” or listing names, position, and responsibilities)
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 information disclosed under the Protective Order: None
Case 1:24-cv-00365-PSH Document 32 Filed 04/15/24 Page 3 of 6
2
7.
I identify here (by writing “none” or identifying the name of the forum, case
number, date, and circumstances) instances in which I have been denied admission to a
protective order, had admission revoked, or have 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.
***
By my signature, I certify that, to the best of my knowledge, the representations set forth
above (including attached statements) are true and correct.
________________________
April 15, 2024
Amy L. Fuentes, Associate
Date Executed
HOLLAND & KNIGHT LLP
1650 Tysons Boulevard – Suite 1700
Tysons, VA 22102-4827
Telephone: (703) 720-8560
Facsimile: (703) 720-8610
Email: Amy.Fuentes@hklaw.com
s/ Eric S. Crusius
April 15, 2024
Eric S. Crusius, Partner
Date Executed
Attorney of Record for
String King Lacrosse LLC
HOLLAND & KNIGHT LLP
1650 Tysons Boulevard – Suite 1700
Tysons, VA 22102-4827
Telephone: (703) 720-8042
Facsimile: (703) 720-8610
Email: Eric.Crusius@hklaw.com
Case 1:24-cv-00365-PSH Document 32 Filed 04/15/24 Page 4 of 6
1
United States Court of Federal Claims
AIRBOSS DEFENSE GROUP, LLC,
)
)
Plaintiff,
)
)
No. 24-365
v.
)
)
Judge Charles F. Lettow
UNITED STATES,
)
)
Defendant.
)
APPLICATION FOR ACCESS TO INFORMATION UNDER
PROTECTIVE ORDER BY OUTSIDE COUNSEL
1.
I, Richard Ariel, 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 Holland & Knight LLP and have been
retained to represent String King Lacrosse LLC, a party to this proceeding.
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
that might gain a competitive advantage from access to the information 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 (by writing “none” or listing names and relevant circumstances)
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 (by writing “none” or listing names, position, and responsibilities)
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 information disclosed under the Protective Order: None
Case 1:24-cv-00365-PSH Document 32 Filed 04/15/24 Page 5 of 6
2
7.
I identify here (by writing “none” or identifying the name of the forum, case
number, date, and circumstances) instances in which I have been denied admission to a
protective order, had admission revoked, or have 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.
***
By my signature, I certify that, to the best of my knowledge, the representations set forth
above (including attached statements) are true and correct.
April 15, 2024
Richard Ariel, Associate
Date Executed
HOLLAND & KNIGHT LLP
800 17th Street NW – Suite 1100
Washington, DC 20006-3962
Telephone: (202) 469-5581
Facsimile: (202) 955-5564
Richard.Ariel@hklaw.com
s/ Eric S. Crusius
April 15, 2024
Eric S. Crusius, Partner
Date Executed
Attorney of Record for
String King Lacrosse LLC
HOLLAND & KNIGHT LLP
1650 Tysons Boulevard – Suite 1700
Tysons, VA 22102-4827
Telephone: (703) 720-8042
Facsimile: (703) 720-8610
Email: Eric.Crusius@hklaw.com
#501456339_v1
Case 1:24-cv-00365-PSH Document 32 Filed 04/15/24 Page 6 of 6