33-8939
Thomas C. Bridge, James D. Edge, and Jeffrey K. Robles (Order Granting Partial Protective Order as to Thomas C. Bridge)
Cite as Securities Act Release No. 33-8939
UNITED STATES OF AMERICA
before the
SECURITIES AND EXCHANGE COMMISSION
SECURITIES ACT OF 1933
Rel. No. 8939 / June 30, 2008
SECURITIES EXCHANGE ACT OF 1934
Rel. No. 58064 / June 30, 2008
INVESTMENT COMPANY ACT OF 1940
Rel. No. 28326 / June 30, 2008
Admin. Proc. File No. 3-12626
In the Matter of
ORDER GRANTING PARTIAL
THOMAS C. BRIDGE,
PROTECTIVE ORDER
JAMES D. EDGE, and
AS TO THOMAS C. BRIDGE
JEFFREY K. ROBLES
On June 3, 2008, Thomas C. Bridge submitted personal financial information to the
Commission in connection with his petition for review of an administrative law judge’s initial
decision and requested a protective order limiting disclosure of this information. 1/ Under
Commission Rule 322, any party “may file a motion requesting a protective order to limit from
disclosure to other parties or to the public documents or testimony that contain confidential
information.” 2/ “A motion for a protective order shall be granted only upon a finding that the
harm resulting from disclosure would outweigh the benefits of disclosure.” 3/ The Division of
Enforcement did not oppose Bridge’s request for a protective order.
1/
17 C.F.R. § 201.322.
2/
17 C.F.R. § 201.322(a).
3/
17 C.F.R. § 201.322(b).
2
The documents Bridge submitted contain sensitive information and, at this stage in the
proceeding, we believe that the harm resulting from complete disclosure outweighs the
benefits. 4/ However, because we have determined that disclosure of certain information
included in the documents will be necessary to our consideration of this proceeding, we shall
grant the requested protected order subject to certain limitations. 5/
Accordingly, IT IS ORDERED that:
1. Except as otherwise provided in this Order, the documents Bridge provided shall be
disclosed only to the parties to this proceeding, their counsel, the Commission, any staff advising
the Commission in its deliberative processes with respect to this proceeding and, in the event of
an appeal of the Commission’s determination, any staff acting for the Commission in connection
with that appeal.
2. All persons who receive access to these documents or the information contained in
these documents shall keep them confidential and, except as provided in this Order, shall not
divulge the documents or information to any person.
3. No person to whom the documents or information covered by the Order is disclosed
shall make any copies or otherwise use such documents or information, except in connection
with this proceeding or any appeal thereof.
4. The Office of the Secretary shall place the documents in sealed envelopes or other
sealed containers marked with the title of this action, identifying each document and marked
“CONFIDENTIAL.”
5. The requirements of sealing and confidentiality shall not apply to any reference to the
existence of the documents or to citation of particular information contained therein in testimony,
oral argument, briefs, opinions, or in any other similar use directly connected with this action or
any appeal thereof.
4/
See Gregory O. Trautman, Securities Exchange Act Rel. No. 57475 (Mar. 11, 2008),
SEC Docket (granting request for order protecting personal financial information in
connection with petition for review and noting that the “harm resulting from complete
disclosure outweighs the benefits”).
5/
See Trautman,
SEC Docket
(determining that disclosure of certain information
included in the documents at issue was necessary to the Commission’s consideration of
the proceeding); Kevin Hall, CPA, Exchange Act Rel. No. 56242 (Aug. 13, 2007), 91
SEC Docket 1071, 1072 (same); David Henry Disraeli, Exchange Act Rel. No. 56012
(July 5, 2007), 90 SEC Docket 3175, 3175 (same).
3
6. The Commission expressly reserves the authority to reach a different conclusion
regarding the confidentiality of the documents or information covered by this Order at any time
before it determines the issues raised in the proceeding.
By the Commission.
Florence E. Harmon
Acting Secretary