Free Motion for Hearing - District Court of Federal Claims - federal

Case 1:07-cv-00881-JPW

Document 41

Filed 02/07/2008

Page 1 of 2

IN THE UNITED STATES
COURT OF FEDERAL CLAIMS
BID PROTEST

SDS INTERNATIONAL, INC. Plaintiff,
v.

USCFC No. 07-881 C
Judge Weise


THE UNITED STATES Defendant.

PLAINTIFF'S REQUEST FOR A HEARING

COMES NOW, Plaintiff SDS International, Inc. ("SDS"), by and through

undersigned counsel, and respectfully requests that the Court conduct a hearing to address the issues raised in SDS' s request for a Preliminary Injunction regarding the award of the contract to HiPK, Inc. SDS requests that the Court convene the hearing at the earliest possible date, recognizing that the Court will need time to review the Pleadings filed in this matter, including SDS's Reply Brief and attachments that SDS is filing in connection with this request.

SDS will make available, at the hearing, SDS's employee William Bayer and SDS's Chief Executive Office George Gennin to provide live testimony and to answer any questions from the Court that concern the assertions in their Affidavits that were filed as Exhibits to SDS' s Reply Brief. SDS will make available via telephone its

consultant, Brian Wages to answer any questions from the court concerning the assertions in his Affidavit.

Case 1:07-cv-00881-JPW

Document 41

Filed 02/07/2008

Page 2 of 2

Mr. Bayer is available to provide live testimony on the SDS's interpretation of the Performance Work Statement and/or Solicitation at issue in this matter and SDS's offer submitted in response to the Solicitation. Mr. Gennin is available to provide live

testimony on the his assertions on irreparable harm to SDS and SDS's ability to transition into the project at issue to assure that the government will not suffer from a break in services. Mr. Wages is available to provide telephone testimony regarding his review of HiPK's proposal, the exhibit attached to HiPK's opposition, and any other documents he reviewed in preparing his Affidavit. Respectfully submitted,
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.sopher Nf.t 6 of}, Centre Law Group, 1953 Gallows Rd, Suite 650 Vienna, VA. 22102 (703) 288-2800 (703) 288-4868 (fax)

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Brian C. Caney-of Counsel

Counsel for Plaintiff SDS International, Inc.

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