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

Case 1:07-cv-00714-GWM

Document 17

Filed 10/19/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL
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CI~AIMS

MASAI TECHNOLOGIES Plaintif, v. THE UNITED STATES Defendant.

CORP.

CoFC No. 07-714 BID PROTEST (Judge George Miller)

MOTION TO SUPPLEMENT THE RECORD AND REQUEST FOR EXPRESS CONSIDERATION COMES NOW the Masai Technologies Corp. ("MTC"), by and through undersigned As more fully

counsel, and hereby files this Motion to Supplement the Record in this matter. described in the Memorandum

in Support of MTC's Motion to Supplement the Record, filed

concurrently herewith, the Court should permit MTC to supplement the record with certain documents that are necessary for the Court to have a complete understanding of the issues in

dispute in this matter as well as the procurement from which this protest arises additionally, the Court's rules state that these documents should be included in the record here. Specifically, MTC seeks to add certain documents which were referenced in MTC's Comments filed with the Government Accountability Office ("GAO") in the prior protest of this matter, Masai Technologies Corp., B-298880.3 et al. Additionally, MTC seeks to include a new affidavit addressing several aspects of the GAO's decision.

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Case 1:07-cv-00714-GWM

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Filed 10/19/2007

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Request for Express Consideratiol! 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 consider this matter on an expedited basis. Were the Court to follow the normal briefing schedule on motions set forth in CFCR 7.2, the issues raised by the present motion could not be resolved before the completion of the main briefing schedule and the hearing scheduled for November 2, 2007. Therefore, MTC respectfully requests 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 the documents requests described that the Court issue an order

the record

and accompanying

MTC's brief

supporting this motion.

Respectfully submitted,

Date:

By: eTS"Oi=-do, Esq. LLC 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

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Counsel for Plaintiff MASAI Technologies Corp.

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Filed 10/19/2007

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CERTIFICATE
th

OF SERVICE

I hereby certify that on this 19 day of October 2007, a copy of the foregoing Motion to Supplement the Record and Request for Express Consideration was served by electronic mail on Counsel for the United States Courtney Sheehan, Esq., United States of Justice, Commercial Litigation Branch, 1100 L Street, N.W.,