Free Motion to Withdraw - District Court of Federal Claims - federal

Case 1:08-cv-00101-LJB

Document 23

Filed 04/18/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST __________________________________________ ) L-3 GLOBAL COMMUNICATIONS ) SOLUTIONS, INC. ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) __________________________________________)

No. 08-101C

CONSENT MOTION TO WITHDRAW PLAINTIFF'S MOTION FOR DISCOVERY AND SUPPLEMENTATION OF THE ADMINISTRATIVE RECORD Counsel for the parties have consulted and agreed to file this Notice to Withdraw Plaintiff's Motion for Discovery and Supplementation of the Administrative Record. Counsel previously advised the Court that they were continuing to work together to resolve the remaining issues regarding supplementation of the Administrative Record. As a result, the Department of Justice has identified additional documents for inclusion in the Administrative Record. Defendant will move to supplement the Administrative Record with these documents. In addition, the parties have agreed for Plaintiff to submit the Declaration of Jeff Myers to describe the activities, events and discussions in connection with the debriefing between Plaintiff and the Coast Guard that was held on December 20, 2007. A consent motion will be filed next week to supplement the Administrative Record with this declaration. Because the parties have reached a mutual resolution of the issues surrounding the gaps in the Administrative Record, Plaintiff no longer needs to proceed with its motion. Accordingly,

Case 1:08-cv-00101-LJB

Document 23

Filed 04/18/2008

Page 2 of 3

Plaintiff hereby withdraws its Motion for Discovery and Supplementation of the Administrative Record. The parties will move to supplement the Administrative Record by April 25, 2008. At that time, the parties will also propose a briefing schedule for further proceedings with this bid protest.

Dated: April 18, 2008

Respectfully submitted,

s/ Ronald K. Henry Ronald K. Henry KAYE SCHOLER, LLP 901 15th Street, NW Suite 1100 Washington, DC 20005 Phone: (202) 682-3500 Fax: (202) 682-3580 [email protected] Attorney for L-3 Global Communications Solutions, Inc.

Case 1:08-cv-00101-LJB

Document 23

Filed 04/18/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that the foregoing was electronically filed on April 18, 2008, with the Clerk of the Court for the United States Court of Federal Claims via the CM/ECF system. This system will send electronic notice of filing to the following individuals:

Dawn S. Conrad Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, DC 20005 Tel: (202) 616-2279 Fax: (202) 305-7643 Attorney for Defendant

s/ Ronald K. Henry Ronald K. Henry KAYE SCHOLER, LLP 901 15th Street, NW Suite 1100 Washington, DC 20005 Phone: (202) 682-3500 Fax: (202) 682-3580 [email protected]

Attorney for L-3 Global Communications Solutions, Inc.