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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES' MOTION FOR ENTRY OF A PROTECTIVE ORDER
Pursuant to Fed. R. Civ. P. 7(b) and D. Del. LR 7.1.1, Plaintiff, the United States, respectfully requests that this Court, pursuant to Fed. R. Civ. P. 26(c)(7), enter a Protective Order, prohibiting Defendant from obtaining the materials requested in its Third Request for Documents, for the reasons stated in the attached brief. Specifically, the United States requests that the Court enter an order that Defendant shall not be able to discover the survey expert materials of the United States until the time for expert discovery, and, consequently, the United States need not produce documents in response to Dentsply's Third Request for Documents. The United States further requests that the Court enter an order that Defendant shall not be entitled, at any time, including during fact and expert discovery, to the identities of the respondents to the survey conducted by the United States' survey expert.
In support of this motion, the United States states that, as shown in the accompanying brief, it has made a reasonable effort to reach agreement with Defendant's attorneys on the subject of this Motion, the result of which was unsuccessful.