Free Motion for Leave to File - District Court of Federal Claims - federal

Case 1:07-cv-00150-GWM

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Filed 04/03/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS (Bid Protest) HERITAGE OF AMERICA, LLC, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-150 (Judge George W. Miller)

CONSENT MOTION TO FILE ABBREVIATED ADMINISTRATIVE RECORD IN HARD COPY Pursuant to Rules 1 and 52.1(a) and Appendix C of the Rules of the United States Court of Federal Claims, the United States, on behalf of all parties, respectfully requests that the Court permit it to file the "Abbreviated Administrative Record" ("AAR") in hard copy.1 The AAR contains all the documents from the

agency record that the parties, at this time, believe are necessary to resolve this bid protest. Filing this "abbreviated

administrative record" will conserve the Court's and the parties' resources. Because it is foreseeable that circumstances may change, the parties respectfully request that they be given the opportunity to file additional appropriate documents from the administrative procurement record if it becomes necessary to do so. The United

We request leave to file in hard copy, pursuant to paragraph I.4 of this Court's General Order 42A, because the volume of the AAR makes it impracticable to file electronically.

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Case 1:07-cv-00150-GWM

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States believes that the proper and most economical mechanism for doing this is by stipulation of the parties, or, if a stipulation is unobtainable, by "motion to supplement the abbreviated administrative record." The procedure envisioned in this motion will best serve the interests of justice and conserve judicial resources. The United

States therefore respectfully requests, on behalf of all parties, that this motion be granted. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director s/ Anuj Vohra for BRIAN T. EDMUNDS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, NW, 8th Floor Telephone: (202)616-8253 Telecopier:(202)307-0972 April 3, 2007 Attorneys for Defendant

Case 1:07-cv-00150-GWM

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Filed 04/03/2007

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CERTIFICATE OF FILING I hereby certify that on April 3, 2007, a copy of foregoing

"CONSENT MOTION TO FILE ABBREVIATED ADMINISTRATIVE RECORD IN HARD COPY" was filed electronically. I understand that notice of this

filing will be sent to all parties by operation of the Court's electronic filing system. the Court's system. Parties may access this filing through

/s Anuj Vohra