Plaintiff's Motion to File Under Seal Its Memorandum in Opposition to Defendant Microsemi's Motion to Dismiss For Improper Venue, Motion to Dismiss for Lack of Personal Jurisdiction, Or, in the Alternative, Motion to Transfer Venue and Exhibits B, C, D...

Date: 
Wednesday, February 4, 2009
Document Type: 
Motions and Memoranda - Miscellaneous
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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
ALEXANDRIA DIVISION


UNITED STATES OF AMERICA,    

                  Plaintiff,

                  v.

MICROSEMI CORPORATION,

                  Defendant.


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Civil Action No. 1:08 CV 1311
Judge: Trenga, Anthony J.
Filed: February 4, 2009

Hearing Date: February 20, 2009



PLAINTIFF'S MOTION TO FILE UNDER SEAL ITS MEMORANDUM IN OPPOSITION TO DEFENDANT MICROSEMI'S MOTION TO DISMISS FOR IMPROPER VENUE, MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION, OR, IN THE ALTERNATIVE, MOTION TO TRANSFER VENUE AND EXHIBITS B, C, D, E, F, G, H, AND I APPENDED THERETO

Plaintiff United States, through its undersigned counsel, respectfully requests that this Court enter an order sealing its Memorandum in Opposition to Defendant Microsemi's Motion to Dismiss for Improper Venue, Motion to Dismiss for Lack of Personal Jurisdiction, or, in the Alternative, Motion to Transfer Venue and Exhibits B, C, D, E, F, G, H, and I appended thereto. The documents at issue contain competitively sensitive information submitted to Plaintiff by the Defendant and a non-party customer of the Defendant's. This relief is sought on an interim basis, pending the entry by the Court of a protective order pursuant to Rule 26(c) of the Federal Rules of Civil Procedure.

    Respectfully submitted,


      _______________/s/________________
LOWELL STERN (VA Bar #33460)
Counsel for the United States
Trial Attorney
Antitrust Division, Litigation II Section
United States Department of Justice
1401 H Street, N.W., Suite 3000
Washington, D.C. 20530
(202) 514-3676
(202) 307-6283 (fax)
Lowell.Stern@usdoj.gov

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 4th day of February, 2009, I will hand deliver the foregoing document to the following:

Brian A. O'Dea
Michael Antalics
Benjamin G. Bradshaw
William T. Buffaloe

O'Melveny & Meyers LLP
1625 Eye Street, N.W.
Washington, DC 20006



      _______________/s/________________
LOWELL STERN (VA Bar #33460)
Counsel for the United States
Trial Attorney
Antitrust Division, Litigation II Section
United States Department of Justice
1401 H Street, N.W., Suite 3000
Washington, D.C. 20530
(202) 514-3676
(202) 307-6283 (fax)
Lowell.Stern@usdoj.gov
Attachments: 
Updated June 30, 2015