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

Case 1:07-cv-00125-MMS

Document 21

Filed 03/30/2007

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United States Court of Federal Claims
______________________________ PROTECTION STRATEGIES, INCORPORATED, Plaintiff v. THE UNITED STATES, Defendant ___________________________ ) ) ) ) ) ) ) ) ) ) ) )

No. 07-125C Judge Margaret M. Sweeney

MOTION FOR PERMISSIVE INTERVENTION
1. Pursuant to RCDC 24(b), PAI requests permission to intervene in the abovecaptioned matter on behalf of PAI, Corporation. 2. I, Steven N. Tomanelli, was retained by PAI Corporation to represent them in this matter on March 5, 2007. I am an attorney in good standing in the State Bars of Virginia, New York and Florida and was admitted to practice before the Court of Federal Claims on March 19, 2007. 3. Protection Strategies, Incorporated ("PSI") filed a protest on February 26, 2007 challenging a contract award made to my client, PAI Corporation on or about December 6, 2006 by the Department of Energy ("DOE"). Consequently, the interests of PAI Corporation would be directly affected if the protest were to be sustained by the Court. 4. The protest filed by PSI alleges, among other things, that PAI is not a responsible contractor, that PAI made material misrepresentations to DOE during the source selection that led to contract award and that PAI's post-award performance violates the terms of the contract. 5. Since its inception in 1983, PAI has built a solid reputation for quality performance and integrity and has won many performance awards over the years. The allegations made by PSI threaten to damage the reputation that PAI has earned. 6. PAI seeks to intervene in this matter for two reasons. First, to retain the contract award that it received after careful consideration by the DOE and, second, to protect its reputation for quality performance and integrity that it worked to develop over twentyfive years.
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Case 1:07-cv-00125-MMS

Document 21

Filed 03/30/2007

Page 2 of 2

WHEREFORE, PAI respectfully requests that the Court grant this Motion to Intervene so that PAI may be independently represented in this matter. *** By my signature, I certify that, to the best of my knowledge, the representations set forth above (including attached statements) are true and correct.

s/ Steven N. Tomanelli Signature of Attorney of Record Steven N. Tomanelli Typed Name and Title 703-405-9327 Telephone Number 703-830-9126 Fax Number

March 26, 2007 Date Executed

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