Free Motion to Intervene - District Court of Federal Claims - federal

Case 1:07-cv-00280-LJB

Document 32

Filed 06/25/2007

Page 1 of 2

UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST

IRONCLAD/EEI, A JOINT VENTURE Plaintiff v. THE UNITED STATES, Defendant

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CIVIL ACTION NO: 07-280C JUDGE: Lynn J. Bush

MOTION TO INTERVENE ON BEHALF OF CROWN ROOFING SERVICES, INC. AND R. L. CAMPBELL ROOFING COMPANY, INC. COMES NOW, the undersigned and files this Motion to Intervene on behalf of Crown Roofing Services, Inc. and R. L. Campbell Roofing Company, Inc. and in support of their Motion, states the following: 1. The plaintiff in the above cited action has filed a protest before this Court alleging

certain improper conduct on the part of the defendant in the award of contracts identified in the plaintiff's Complaint. Intervenors, Crown Roofing Services, Inc., and R. L. Campbell Roofing Company, Inc., were awarded contracts identified by the plaintiff. Crown Roofing Services, Inc. and R. L. Campbell Roofing Company, Inc., claim an interest relating to the property or transaction which are the subject of the action and, are so situated that the disposition of the action may, as a practical matter, impair or impede Crown Roofing Services, Inc.'s and R. L. Campbell Roofing Company, Inc.'s ability to protect that interest. Crown Roofing Services, Inc. and R. L. Campbell Roofing Company, Inc. are, therefore, entitled to intervene in this litigation. 2. Intervenors, Crown Roofing Services, Inc. and R. L. Campbell Roofing Company,

Inc. respectfully request that this Court place the undersigned on its list of recipients for any filings, whether paper or electronic. The undersigned states that he is a member of the Bar of the United

Case 1:07-cv-00280-LJB

Document 32

Filed 06/25/2007

Page 2 of 2

States Court of Federal Claims. 3. Counsel for the United States has been advised of Crown Roofing Services, Inc.'s and

R. L. Campbell Roofing Company, Inc.'s intention to intervene in this matter and has no objection to such intervention. Crown Roofing Services, Inc. and R. L. Campbell Roofing Company, Inc. have received a copy of this Court's Scheduling Order and presently foresee no reason for any delay of the schedule outlined by the Court. Submitted, this 25th day of June, 2007.

Respectfully submitted, /Herman C. Hoffmann, Jr. HERMAN C. HOFFMANN, JR. (6899) WADE M. BASS (29081) SIMON, PERAGINE, SMITH & REDFEARN, L.L.P. 1100 Poydras Street, 30th Floor New Orleans, LA 70163 Telephone: 504/569-2030 Facsimile: 504/569-2999 e-mail: [email protected] e-mail: [email protected]

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