Free Notice (Other) - District Court of Federal Claims - federal

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 1 of 18

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST

) LOGISTICS SUPPORT SERVICES JV, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES ) OF AMERICA, ) ) Defendant. )

Civil Action No. 07-897 Judge Hewitt

APPLICATION FOR ACCESS TO INFORMATION UNDER PROTECTIVE ORDER BY OUTSIDE COUNSEL 1. I, Russell Gaspar, hereby apply for access to protected information

covered by the Protective Order issued in connection with this proceeding. 2. I am an attorney with the law firm of Cohen Mohr LLP and have been

retained to represent Logistics Support Services JV, a party to this proceeding. 3. (the court). 4. My professional relationship with the party I represent in this proceeding I am a member of the bar of the United States Court of Federal Claims

and its personnel is strictly one of legal counsel. I am not involved in competitive decision making as discussed in U.S. Steel Corp. v. United States, 730 F.2d 1465 (Fed. Cir. 1984), for or on behalf of the party I represent, any entity that is an interested party to this proceeding, or any other firm that might gain a competitive advantage from access to the information disclosed under the Protective Order. I do not provide advice or participate in any decisions of such parties in matters involving similar or corresponding

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 2 of 18

information about a competitor. This means that I do not, for example, provide advice concerning, or participate in decisions about, marketing or advertising strategies, product research and development, product design or competitive structuring and composition of bids, offers, or proposals with respect to which the use of protected. information could provide a competitive advantage. 5. I identify here (by writing "none" or listing names and relevant

circumstances) those attorneys in my firm who, to the best of my knowledge, cannot make the representations set forth in the preceding paragraph: None. 6. I identify here (by writing "none" or listing names, position, and

responsibilities) any member of my immediate family who is an officer or holds a management position with an interested party in the proceeding or with any other firm that might gain a competitive advantage from access to the information disclosed under the Protective Order: None. 7. I identify here (by writing "none" or identifying the name of the forum,

case number, date, and circumstances) instances in which I have been denied admission to a protective order, had admission revoked, or have been found to have violated a protective order issued by any administrative or judicial tribunal: None. 8. 9. Not applicable I have read the Protective Order issued by the court in this proceeding. I

will comply in all respects with that order and will abide by its terms and conditions in

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 3 of 18

handling any protected information produced in connection with the proceeding. 10. I acknowledge that a violation of the terms of the Protective Order may

result in the imposition of such sanctions as may be deemed appropriate by the court and in possible civil and criminal liability. * * *

By my signature, I certify that, to the best of my knowledge, the representations set forth above (including attached statements) are true and correct.

___s/ Russell Gaspar_______ Russell Gaspar, Attorney (202) 342-2550, Telephone (202) 342-6147, Facsimile __ s/ David S. Cohen______ David S. Cohen, Attorney of Record (202) 342-2550, Telephone (202) 342-6147, Facsimile

December 28, 2007 Date Executed

December 28, 2007 Date Executed

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 4 of 18

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST

) LOGISTICS SUPPORT SERVICES JV, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES ) OF AMERICA, ) ) Defendant. )

Civil Action No. 07-897 Judge Hewitt

APPLICATION FOR ACCESS TO INFORMATION UNDER PROTECTIVE ORDER BY OUTSIDE COUNSEL 1. I, Bryan Bunting, hereby apply for access to protected information

covered by the Protective Order issued in connection with this proceeding. 2. I am an attorney with the law firm of Cohen Mohr LLP and have been

retained to represent Logistics Support Services JV, a party to this proceeding. 3. I am not a member of the bar of the United States Court of Federal

Claims (the court). 4. My professional relationship with the party I represent in this proceeding

and its personnel is strictly one of legal counsel. I am not involved in competitive decision making as discussed in U.S. Steel Corp. v. United States, 730 F.2d 1465 (Fed. Cir. 1984), for or on behalf of the party I represent, any entity that is an interested party to this proceeding, or any other firm that might gain a competitive advantage from access to the information disclosed under the Protective Order. I do not provide advice or participate in any decisions of such parties in matters involving similar or corresponding

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 5 of 18

information about a competitor. This means that I do not, for example, provide advice concerning, or participate in decisions about, marketing or advertising strategies, product research and development, product design or competitive structuring and composition of bids, offers, or proposals with respect to which the use of protected. information could provide a competitive advantage. 5. I identify here (by writing "none" or listing names and relevant

circumstances) those attorneys in my firm who, to the best of my knowledge, cannot make the representations set forth in the preceding paragraph: None. 6. I identify here (by writing "none" or listing names, position, and

responsibilities) any member of my immediate family who is an officer or holds a management position with an interested party in the proceeding or with any other firm that might gain a competitive advantage from access to the information disclosed under the Protective Order: None. 7. I identify here (by writing "none" or identifying the name of the forum,

case number, date, and circumstances) instances in which I have been denied admission to a protective order, had admission revoked, or have been found to have violated a protective order issued by any administrative or judicial tribunal: None. 8. 9. Not applicable I have read the Protective Order issued by the court in this proceeding. I

will comply in all respects with that order and will abide by its terms and conditions in

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 6 of 18

handling any protected information produced in connection with the proceeding. 10. I acknowledge that a violation of the terms of the Protective Order may

result in the imposition of such sanctions as may be deemed appropriate by the court and in possible civil and criminal liability. * * *

By my signature, I certify that, to the best of my knowledge, the representations set forth above (including attached statements) are true and correct.

__ s/ Bryan Bunting ______ David S. Cohen, Attorney (202) 342-2550, Telephone (202) 342-6147, Facsimile __ s/ David S. Cohen______ David S. Cohen, Attorney of Record (202) 342-2550, Telephone (202) 342-6147, Facsimile

December 28, 2007 Date Executed

December 28, 2007 Date Executed

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 7 of 18

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST

) LOGISTICS SUPPORT SERVICES JV, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES ) OF AMERICA, ) ) Defendant. )

Civil Action No. 07-897 Judge Hewitt

APPLICATION FOR ACCESS TO INFORMATION UNDER PROTECTIVE ORDER BY OUTSIDE COUNSEL 1. I, John J. O'Brien, hereby apply for access to protected information

covered by the Protective Order issued in connection with this proceeding. 2. I am an attorney with the law firm of Cohen Mohr LLP and have been

retained to represent Logistics Support Services JV, a party to this proceeding. 3. (the court). 4. My professional relationship with the party I represent in this proceeding I am a member of the bar of the United States Court of Federal Claims

and its personnel is strictly one of legal counsel. I am not involved in competitive decision making as discussed in U.S. Steel Corp. v. United States, 730 F.2d 1465 (Fed. Cir. 1984), for or on behalf of the party I represent, any entity that is an interested party to this proceeding, or any other firm that might gain a competitive advantage from access to the information disclosed under the Protective Order. I do not provide advice or participate in any decisions of such parties in matters involving similar or corresponding

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 8 of 18

information about a competitor. This means that I do not, for example, provide advice concerning, or participate in decisions about, marketing or advertising strategies, product research and development, product design or competitive structuring and composition of bids, offers, or proposals with respect to which the use of protected. information could provide a competitive advantage. 5. I identify here (by writing "none" or listing names and relevant

circumstances) those attorneys in my firm who, to the best of my knowledge, cannot make the representations set forth in the preceding paragraph: None. 6. I identify here (by writing "none" or listing names, position, and

responsibilities) any member of my immediate family who is an officer or holds a management position with an interested party in the proceeding or with any other firm that might gain a competitive advantage from access to the information disclosed under the Protective Order: None. 7. I identify here (by writing "none" or identifying the name of the forum,

case number, date, and circumstances) instances in which I have been denied admission to a protective order, had admission revoked, or have been found to have violated a protective order issued by any administrative or judicial tribunal: None. 8. 9. Not applicable I have read the Protective Order issued by the court in this proceeding. I

will comply in all respects with that order and will abide by its terms and conditions in

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 9 of 18

handling any protected information produced in connection with the proceeding. 10. I acknowledge that a violation of the terms of the Protective Order may

result in the imposition of such sanctions as may be deemed appropriate by the court and in possible civil and criminal liability. * * *

By my signature, I certify that, to the best of my knowledge, the representations set forth above (including attached statements) are true and correct.

___s/ John J. O'Brien______ John J. O'Brien, Attorney (202) 342-2550, Telephone (202) 342-6147, Facsimile __ s/ David S. Cohen______ David S. Cohen, Attorney of Record (202) 342-2550, Telephone (202) 342-6147, Facsimile

December 28, 2007 Date Executed

December 28, 2007 Date Executed

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 10 of 18

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST

) LOGISTICS SUPPORT SERVICES JV, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES ) OF AMERICA, ) ) Defendant. )

Civil Action No. 07-897 Judge Hewitt

APPLICATION FOR ACCESS TO INFORMATION UNDER PROTECTIVE ORDER BY OUTSIDE COUNSEL 1. I, Laurel Hockey, hereby apply for access to protected information

covered by the Protective Order issued in connection with this proceeding. 2. I am an attorney with the law firm of Cohen Mohr LLP and have been

retained to represent Logistics Support Services JV, a party to this proceeding. 3. (the court). 4. My professional relationship with the party I represent in this proceeding I am a member of the bar of the United States Court of Federal Claims

and its personnel is strictly one of legal counsel. I am not involved in competitive decision making as discussed in U.S. Steel Corp. v. United States, 730 F.2d 1465 (Fed. Cir. 1984), for or on behalf of the party I represent, any entity that is an interested party to this proceeding, or any other firm that might gain a competitive advantage from access to the information disclosed under the Protective Order. I do not provide advice or participate in any decisions of such parties in matters involving similar or corresponding

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 11 of 18

information about a competitor. This means that I do not, for example, provide advice concerning, or participate in decisions about, marketing or advertising strategies, product research and development, product design or competitive structuring and composition of bids, offers, or proposals with respect to which the use of protected. information could provide a competitive advantage. 5. I identify here (by writing "none" or listing names and relevant

circumstances) those attorneys in my firm who, to the best of my knowledge, cannot make the representations set forth in the preceding paragraph: None. 6. I identify here (by writing "none" or listing names, position, and

responsibilities) any member of my immediate family who is an officer or holds a management position with an interested party in the proceeding or with any other firm that might gain a competitive advantage from access to the information disclosed under the Protective Order: None. 7. I identify here (by writing "none" or identifying the name of the forum,

case number, date, and circumstances) instances in which I have been denied admission to a protective order, had admission revoked, or have been found to have violated a protective order issued by any administrative or judicial tribunal: None. 8. 9. Not applicable I have read the Protective Order issued by the court in this proceeding. I

will comply in all respects with that order and will abide by its terms and conditions in

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 12 of 18

handling any protected information produced in connection with the proceeding. 10. I acknowledge that a violation of the terms of the Protective Order may

result in the imposition of such sanctions as may be deemed appropriate by the court and in possible civil and criminal liability. * * *

By my signature, I certify that, to the best of my knowledge, the representations set forth above (including attached statements) are true and correct.

__ s/ Laurel Hockey______ Laurel Hockey, Attorney (202) 342-2550, Telephone (202) 342-6147, Facsimile __ s/ David S. Cohen______ David S. Cohen, Attorney of Record (202) 342-2550, Telephone (202) 342-6147, Facsimile

December 28, 2007 Date Executed

December 28, 2007 Date Executed

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 13 of 18

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST

) LOGISTICS SUPPORT SERVICES JV, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES ) OF AMERICA, ) ) Defendant. )

Civil Action No. 07-897 Judge Hewitt

APPLICATION FOR ACCESS TO INFORMATION UNDER PROTECTIVE ORDER BY OUTSIDE COUNSEL 1. I, David S. Cohen, hereby apply for access to protected information

covered by the Protective Order issued in connection with this proceeding. 2. I am an attorney with the law firm of Cohen Mohr LLP and have been

retained to represent Logistics Support Services JV, a party to this proceeding. 3. (the court). 4. My professional relationship with the party I represent in this proceeding I am a member of the bar of the United States Court of Federal Claims

and its personnel is strictly one of legal counsel. I am not involved in competitive decision making as discussed in U.S. Steel Corp. v. United States, 730 F.2d 1465 (Fed. Cir. 1984), for or on behalf of the party I represent, any entity that is an interested party to this proceeding, or any other firm that might gain a competitive advantage from access to the information disclosed under the Protective Order. I do not provide advice or participate in any decisions of such parties in matters involving similar or corresponding

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 14 of 18

information about a competitor. This means that I do not, for example, provide advice concerning, or participate in decisions about, marketing or advertising strategies, product research and development, product design or competitive structuring and composition of bids, offers, or proposals with respect to which the use of protected. information could provide a competitive advantage. 5. I identify here (by writing "none" or listing names and relevant

circumstances) those attorneys in my firm who, to the best of my knowledge, cannot make the representations set forth in the preceding paragraph: None. 6. I identify here (by writing "none" or listing names, position, and

responsibilities) any member of my immediate family who is an officer or holds a management position with an interested party in the proceeding or with any other firm that might gain a competitive advantage from access to the information disclosed under the Protective Order: None. 7. I identify here (by writing "none" or identifying the name of the forum,

case number, date, and circumstances) instances in which I have been denied admission to a protective order, had admission revoked, or have been found to have violated a protective order issued by any administrative or judicial tribunal: None. 8. 9. Not applicable I have read the Protective Order issued by the court in this proceeding. I

will comply in all respects with that order and will abide by its terms and conditions in

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 15 of 18

handling any protected information produced in connection with the proceeding. 10. I acknowledge that a violation of the terms of the Protective Order may

result in the imposition of such sanctions as may be deemed appropriate by the court and in possible civil and criminal liability. * * *

By my signature, I certify that, to the best of my knowledge, the representations set forth above (including attached statements) are true and correct.

___s/ David S. Cohen______ John J. O'Brien, Attorney (202) 342-2550, Telephone (202) 342-6147, Facsimile __ s/ David S. Cohen______ David S. Cohen, Attorney of Record (202) 342-2550, Telephone (202) 342-6147, Facsimile

December 28, 2007 Date Executed

December 28, 2007 Date Executed

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 16 of 18

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST

) LOGISTICS SUPPORT SERVICES JV, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES ) OF AMERICA, ) ) Defendant. )

Civil Action No. 07-897 Judge Hewitt

APPLICATION FOR ACCESS TO INFORMATION UNDER PROTECTIVE ORDER BY OUTSIDE COUNSEL 1. I, Kelly Kroll, hereby apply for access to protected information covered

by the Protective Order issued in connection with this proceeding. 2. I am an attorney with the law firm of Cohen Mohr LLP and have been

retained to represent Logistics Support Services JV, a party to this proceeding. 3. (the court). 4. My professional relationship with the party I represent in this proceeding I am a member of the bar of the United States Court of Federal Claims

and its personnel is strictly one of legal counsel. I am not involved in competitive decision making as discussed in U.S. Steel Corp. v. United States, 730 F.2d 1465 (Fed. Cir. 1984), for or on behalf of the party I represent, any entity that is an interested party to this proceeding, or any other firm that might gain a competitive advantage from access to the information disclosed under the Protective Order. I do not provide advice or participate in any decisions of such parties in matters involving similar or corresponding

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 17 of 18

information about a competitor. This means that I do not, for example, provide advice concerning, or participate in decisions about, marketing or advertising strategies, product research and development, product design or competitive structuring and composition of bids, offers, or proposals with respect to which the use of protected. information could provide a competitive advantage. 5. I identify here (by writing "none" or listing names and relevant

circumstances) those attorneys in my firm who, to the best of my knowledge, cannot make the representations set forth in the preceding paragraph: None. 6. I identify here (by writing "none" or listing names, position, and

responsibilities) any member of my immediate family who is an officer or holds a management position with an interested party in the proceeding or with any other firm that might gain a competitive advantage from access to the information disclosed under the Protective Order: None. 7. I identify here (by writing "none" or identifying the name of the forum,

case number, date, and circumstances) instances in which I have been denied admission to a protective order, had admission revoked, or have been found to have violated a protective order issued by any administrative or judicial tribunal: None. 8. 9. Not applicable I have read the Protective Order issued by the court in this proceeding. I

will comply in all respects with that order and will abide by its terms and conditions in

Case 1:07-cv-00897-ECH

Document 20

Filed 12/28/2007

Page 18 of 18

handling any protected information produced in connection with the proceeding. 10. I acknowledge that a violation of the terms of the Protective Order may

result in the imposition of such sanctions as may be deemed appropriate by the court and in possible civil and criminal liability. * * *

By my signature, I certify that, to the best of my knowledge, the representations set forth above (including attached statements) are true and correct.

__ s/ Kelly Kroll______ Kelly Kroll, Attorney (202) 342-2550, Telephone (202) 342-6147, Facsimile __ s/ David S. Cohen______ David S. Cohen, Attorney of Record (202) 342-2550, Telephone (202) 342-6147, Facsimile

December 28, 2007 Date Executed

December 28, 2007 Date Executed