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UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS


EASTERN DIVISION

____________________________________
)
UNITED STATES OF AMERICA )
) Civil Action No. 05 C 5140
Plaintiff, )
) Judge Filip
v. )
) Magistrate Judge Denlow
NATIONAL ASSOCIATION OF )
REALTORS )
)
Defendant. )
____________________________________)

UNITED STATES’ MOTION FOR ENTRY OF PROTECTIVE ORDER

Plaintiff, the United States, respectfully moves the Court, pursuant to Fed. R. Civ. P.

26(c)(7), to enter the attached, proposed Protective Order, for the reasons stated in Plaintiff’s

accompanying memorandum.

Pursuant to Local Rule 37.2, Plaintiff makes the following statement of efforts to reach

an accord: Counsel for the United States and counsel for National Association of Realtors

consulted at length by telephone and e-mail and made good faith attempts to resolve differences,

but were unable to reach an accord. These telephone consultations occurred on November 4,

2005, November 15, 2005 (12 p.m. EST), November 21, 2005 (4 p.m. EST), and November 29,

2005 (12 p.m. EST).


Respectfully submitted,

/s/Craig W. Conrath
Craig W. Conrath
David C. Kully
Carol A. Bell
U.S. Department of Justice
Antitrust Division
325 Seventh Street, N.W., Suite 300
Washington, D.C. 20530
Tel: (202) 307-5779
Fax: (202) 307-9952

COUNSEL FOR PLAINTIFF


UNITED STATES OF AMERICA

Dated: December 23, 2005