Free Motion to Supplement the Administrative Record - District Court of Federal Claims - federal


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Case 1:07-cv-00714-GWM

Document 24

Filed 10/29/2007

Page 1 of 3

IN THE UNITED STATES
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OF FED]8~RAL CLAIMS

MASAI TECHNOLOGIES Plaintif,
v.

CORP.

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THE UNITED STATES Defendant.
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CoFC No. 07-714 BID PROTEST (Judge George Miller)

PLAINTIFF'S SECOND MOTION TO SUPPLEMENT THE RECORD AND REQUEST FOR EXPRESS CONSIDERATION COMES NOW the Masai Technologies Corp. ("MTC"), by and through undersigned counsel, and hereby files this Second Motion to Supplement the Record in this matter. As more fully described in the Memorandum Support of MTC's Motion to Supplement the Record,

filed concurrently herewith, the Court should permit MTC to supplement the record with the enclosed correspondence from the Department of the Interior, dated April 23, 2007, Exhibit 1

hereto, because this document is necessary for the Court to have a complete understanding of the issues in dispute in this matter as as the procurement from which this protest arises

additionally, this document is presented in response to the Declaration of David Ray which accompanied the Government's Government's Brief. Brief in this matter as well as the arguments presented in the

Case 1:07-cv-00714-GWM

Document 24

Filed 10/29/2007

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Request for Express Consideration Due to the compressed pleading schedule set forth for this litigation in the Court's

Scheduling Order, dated October 5, 2007, MTC respectfully requests that the Court considcr this mattcr on an expedited basis. Were the Court to follow the normal briefing schedule on motions sct forth in CFCR 7.2, the issues raised by the present motion could not be resolved before the hearing scheduled for November 2, 2007. Therefore, MTC respectfully requests that the Court resolve this matter within sufficient time so that MTC may use the materials supplementing the record in its briefings before the Court and at the scheduled hearing. WHEREFORE supplementing Plaintiff respectfully requests described that the Court issue an order

the record with the documents

and accompanying

MTC's brief

supporting this motion.

Respectfully

Date:

By: ~ 0, Esq. s Legal, LLC 5 Center St. Suite 307 Manassas, VA 20110 (703) 368-8770 fax (703) 368-8772 Janine Benton, of Counsel Benton & Potter 150 S. Washington St Suite 202 Falls Church, VA 22046 lame

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Counsel for Plaintiff MASAI 'rechnologies Corp.

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Case 1:07-cv-00714-GWM

Document 24

Filed 10/29/2007

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CERTIFICA TE OF SERVICE I hereby certify that on this 29 day of October 2007, a copy of the foregoing Plaintiff's Second Motion to Supplement the Record and Request for Express Consideration was served by electronic mail on Counsel for the United States Courtney United States Department of Justice, Commercial Litigation Branch, 1100 L S DC 20530.
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