UNITED STATES DISTRICT COURTMIDDLE DISTRICT OF FLORIDA
IN RE TRI-STATE WATER RIGHTSLITIGATIONMDL Case No. 1824Case No. 3:07-md-01 (PAM/JRK)
Joint Motion for Order RegardingConfidentiality of Settlement Negotiations
The States of Alabama, Florida, and Georgia respectfully request that this Court issue anOrder declaring that ongoing settlement negotiations among the three States, including relatednegotiations with any other party to this litigation, as well as any documents, data or othermaterials prepared in anticipation of or exchanged in the course of such negotiations, and allstatements made during the negotiations, are and shall be kept confidential. In support of thismotion, the three States state as follows:1.
On December 15, 2009, the Governors of the States of Alabama, Florida andGeorgia met to discuss possible resolution of issues involved in this litigation. The threeGovernors have directed their staffs to engage in expedited discussions designed to determinewhether a negotiated solution is possible at this time. The three States intend to pursue thosenegotiations in the coming months, and at least five meetings are currently scheduled.2.
Although the three States already have commenced confidential negotiations, theybelieve a court order declaring the confidential nature of their discussions may encourage theopen exchange of information and proposals necessary to address the issues at bar, anddiscourage the improper dissemination of the same.3.
The three States anticipate that, from time to time, they might need to include intheir discussions other parties to this litigation, as well as non-parties, if necessary. If the Court
Case 3:07-md-00001-PAM-JRK Document 315 Filed 01/04/2010 Page 1 of 8