Free Motion for Miscellaneous Relief - District Court of Federal Claims - federal

Case 1:07-cv-00897-ECH

Document 33

Filed 01/09/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST

) LOGISTICS SUPPORT SERVICES JV, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES ) OF AMERICA, ) ) Defendant. ) ) and ) ) SANTA BARBARA ) APPLIED RESEARCH, INC., ) ) Intervenor )

Civil Action No. 07-897 (Judge Emily C. Hewitt)

PLAINTIFF'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS OR IN THE ALTERNATIVE TO SUPPLEMENT THE ADMINISTRATIVE RECORD AND TO REVISE THE COURT'S DECEMBER 27, 2007 SCHEDULING ORDER COMES NOW Plaintiff Logistics Support Services JV ("LSSJV"), by and through the undersigned counsel, and hereby moves this Court to compel production or in the alternative to supplement the administrative record and to revise the Court's December 27, 2007 scheduling order to facilitate supplementation of the administrative record. The grounds for this motion and the relief requested are further detailed in the memorandum of points and authorities in support of this motion being filed herewith.

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Case 1:07-cv-00897-ECH

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WHEREFORE Plaintiff requests the Court to grant this motion and order the additional discovery and document production requested in the attached memorandum of points and authorities.

Respectfully submitted,

By: s/David S. Cohen David S. Cohen Cohen Mohr, LLP 1055 Thomas Jefferson St., NW Suite 504 Washington, DC 20007 (202) 342-2550 (telephone) (202) 342-6147 (facsimile) Attorney of Record for Plaintiff Logistics Support Services JV Of Counsel: John J. O'Brien Cohen Mohr, LLP 1055 Thomas Jefferson St., NW Suite 504 Washington, DC 20007 (202) 342-2550 (telephone) (202) 342-6147 (facsimile) Dated: January 9, 2008

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Case 1:07-cv-00897-ECH

Document 33

Filed 01/09/2008

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Certificate of Filing I hereby certify that on this 9th day of January 2008, a copy of the foregoing "Plaintiff's Motion To Compel Production Of Documents Or In The Alternative To Supplement The Administrative Record And To Revise The Court's December 27, 2007 Scheduling Order," was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system

s/David S. Cohen David S. Cohen

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