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

Case 1:07-cv-00322-JPW

Document 15

Filed 06/18/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL

CLAIMS

INPUT/OUTPUT TECHNOLOGY, Plaintiff, v. THE UNITED STATES Defendant.
----------

INC.

I I I

I
I I I
CoFC No. 07-322 BID PROTEST (Judge Wiese)

I
I I
-.1

MOTION

TO SUPPLEMENT

THE RECORD

COMES NOW Plaintiff the Input/Output Technology, Inc. ("10 Tech"), by and through undersigned counsel, and hereby files this Motion to Supplement the Record in this matter. The attached Declaration of Thad Drapala enclosed hereto as Exhibit,

provides the Plaintiff's

response to the declarations and information submitted by the As the Court has directed, Mr. Drapala's declaration is

Government in this matter.

necessary for the Court to have a complete understanding of the issues at the heart of the dispute in this matter as well as the procurement from which this protest arises. Drapala's declaration demonstrates that the Government's Mr.

persollilel do not understand

the nature of the items being procured in this procurement, and that the Government has failed to follow its own procedures in approving an alternate offeror for the item sought in this procurement. WHEREFORE Plaintiff respectfully requests that the Court Issue an order

supplementing the record with the documents described.

Case 1:07-cv-00322-JPW

Document 15

Filed 06/18/2007

Page 2 of 3

Respectfully submitted

Date:

By:

JamesKDelSordo, Esq. Argus Legal, LLC 9255 Center St. Suite 307 Manassas, VA 20110 (703) 368-8770 fax (703) 368-8772 Counsel for Plaintiff Input/Output Technology, Inc.

~

,//:'1

/

/'/

/

,,~------

2

Case 1:07-cv-00322-JPW

Document 15

Filed 06/18/2007

Page 3 of 3

CERTIFICATE

OF SERVICE

I hereby certify that on this 18th day of June, 2007, a copy ofthe foregoing Motion to Supplement the Record was served by electronic mail on Counsel for the United States James Poirier, Esq., United States Department of Justice, Commercial Branch, 1100 L Street, N.W., Washington, DC 20530.

3