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