Replies to post #308400 on Fannie Mae-No Politics (FNMA)

[Hvp123]

Nothing important, just some changes in wordings used, no big deal :)
You know lawyers think deeply, than us :)

[Dollars1]

v. ) No. 13-465C ) (Judge Sweeney) ) IN THE UNITED STATES COURT OF FEDERAL CLAIMS FAIRHOLME FUNDS, INC., et al., ) ) Plaintiffs, ) THE UNITED STATES, ) ) Defendant. ) PLAINTIFFS’ UNOPPOSED MOTION TO AMEND THE PROTECTIVE ORDER Pursuant to this Court’s July 10, 2015 order in Cacciapalle, et al., v. United States, No. 13-466C (Fed. Cl.), and related cases, Plaintiffs respectfully move to amend this Court’s July 16, 2014 Protective Order (Doc. 73). In accordance with this Court’s instructions, Plaintiffs attach a proposed Amended Protective Order (Exhibit A) and a copy of the original Protective Order with suggested changes indicated (Exhibit B). The suggested changes have been agreed upon by all counsel in the actions specified in this Court’s July 10 Cacciapalle order. Date: July 27, 2015 Of counsel: Vincent J. Colatriano David H. Thompson Peter A. Patterson Brian W. Barnes COOPER & KIRK, PLLC 1523 New Hampshire Avenue, N.W. Washington, D.C. 20036 [phone] [phone] (fax) Respectfully submitted, s/ Charles J. Cooper Charles J. Cooper Counsel of Record COOPER & KIRK, PLLC 1523 New Hampshire Avenue, N.W. Washington, D.C. 20036 [phone] [phone] (fax) [e-mail]
copy of the foregoing was served upon all counsel of record on this 27th day of July, 2015, via the Court’s Electronic Case Filing system. s/ Charles J. Cooper Charles J. Cooper

[Dollars1]

I just copied one of the pages you might think interesting, where they added to specified parties, etc.

Protected Information, and all parties and non-parties shall abide by the terms of this Protective Order with respect to such information. This Protective Order shall not protect from disclosure or permit the protected designation of any document, information or material that: (a) the party has not made reasonable efforts to keep confidential; or (b) has been produced in any other action or proceeding without confidentiality protection, except inadvertently produced documents. 1. Parties. For the purposes of this Protective Order, the term “party” or “parties” shall refer only to the plaintiffs in Fairholme Funds, Inc. et al v. United States (No. 13-465C, Fed. Cl.), Cacciapalle, et al. v. United States, (No. 13-466C, Fed. Cl.),13-465, Fed. Reid v. United States, (No. 14-152C, Fed. Cl.), Washington Federal, et al. v. United States (No. 13-385C, Fed. Cl.), Fisher v. United States, (No. 13-608C, Fed. Cl.), Rafter v. United States (No. 14-740C, Fed. Cl.), and Arrowood Indemnity Company, et al. v. United States (No. 13-698C, Fed. Cl.) (the “Actions”)Cl.), and defendant, the United States, including its agencies. For the purposes of this Protective Order, the term “party” shall also include the Federal Housing Finance Agency (FHFA). The inclusion of FHFA in this definition does not imply or state that FHFA is a defendant, or that FHFA is a Government actor for all purposes. For purposes of this Protective Order, the term “producing party” includes non-parties that produce material that has been designated as Protective Information. 2. Protected Information Defined. “Protected Information” as used in this Protective Order means proprietary, confidential, trade secret, or market-sensitive information, as well as information that is otherwise protected from public disclosure under applicable law. Protected Information does not include discovery material that has been provided to or prepared by any Government agency (which shall include, for these purposes, FHFA) and that is available under applicable law. The designation of information as Protected Information must be made or supervised by an attorney. To facilitate the expeditious production by a party of information requested in discovery by another party, the producing party may initially designate all information that it produces as Protected Information, subject to the right of the receiving party, in accordance with the procedures established under Paragraph 17 of this Protective Order, to thereafter challenge the designation of the information as Protected Information. Protected Information may be contained in: (a) any document produced, filed, or served by a party to this litigation (the term “document” is defined to include, without limitation, all written, recorded, or graphic material, whether produced or created by a party or another person, whether produced pursuant to Rule 34 of the Rules of this court, subpoena, by agreement, or otherwise); or (b) any deposition, sealed testimony or argument, declaration, or affidavit taken or provided during this litigation; 3. Restrictions on the Use of Protected Information. Protected Information may be used solely for the purposes of Fairholme Funds, Incthe Actions identified in Paragraph 1,. v. United States (No. 13-465, Fed. Cl.), including any appellate proceedings, and may not be given, shown, made available, discussed, or otherwise conveyed in any form, except as otherwise agreed by the parties or as otherwise provided in this Protective Order or in any subsequent orders issued by the court in this action (including but not limited to any orders issued pursuant to Paragraphs 17