UNITED STATES OF AMERICA v. AT&T INC. et al

Filing 76

Unopposed MOTION for Protective Order Concerning Confidentiality by UNITED STATES OF AMERICA (Attachments: # 1 Text of Proposed Order Second Amended Stipulated Protective Order Concerning Confidentiality, # 2 Exhibit Ex. 1 Changes to Amended Protective Order)(Hammond, Matthew)

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA et al.,
Plaintiffs,

Civil Action No. 11-01560 (ESH)

v.
AT&T INC. et al.,
Defendants.

UNITED STATES’ UNOPPOSED MOTION TO ENTER SECOND AMENDED
STIPULATED PROTECTIVE ORDER CONCERNING CONFIDENTIALITY
Plaintiff, the United States of America, respectfully moves the Court, pursuant to Fed. R.
Civ. P. 26(c)(1)(G), to enter the attached, proposed Second Amended Stipulated Protective Order
Concerning Confidentiality. Entry of the proposed Order would resolve issues raised in nonparty Google Inc.’s Motion for Additional Relief under the Protective Order, and also makes
minor changes, recognizing, for instance, the appointment of Special Master Levie. A version of
the proposed Order showing the proposed changes to the existing Protective Order is also
attached. Pursuant to LCvR 7(m), counsel for the parties and non-party Google have conferred
and none oppose this motion.

Dated this 8th day of November 2011.
Respectfully submitted,
FOR PLAINTIFF UNITED STATES OF AMERICA:
__/s/ Matthew C. Hammond__________
Matthew C. Hammond
Attorney
U.S. Department of Justice, Antitrust Division
Telecommunications & Media
Enforcement Section
450 Fifth Street, N.W., Suite 7000
Washington, DC 20530
Phone: [phone]
Facsimile: [phone]
[e-mail]

CERTIFICATE OF SERVICE
I, Matthew C. Hammond, hereby certify that on November 8, 2011, I caused a true and correct
copy of the foregoing United States’ Unopposed Motion to Enter Second Amended Stipulated
Protective Order Concerning Confidentiality to be served via electronic mail on:
For Defendant AT&T Inc.:
Steven F. Benz
Kellogg, Huber, Hansen, Todd, Evans & Figel, P.L.L.C.
[e-mail]
For Defendants T-Mobile USA, Inc. and Deutsche Telekom AG:
Patrick Bock
Cleary Gottlieb Steen & Hamilton LLP
[e-mail]
For Plaintiff States:
Geralyn J. Trujillo
Office of the Attorney General, State of New York
[e-mail]
David M. Kerwin
Office of the Attorney General, State of Washington
[e-mail]
For Google, Inc.:
John D. Harkrider
Daniel S. Bitton
Axinn, Veltrop & Harkrider LLP

/s/ Matthew C. Hammond