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

Case 1:07-cv-00090-ECH

Document 11

Filed 02/14/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS Bid Protest ____________________________________ ) R&D DYNAMICS CORPORATION, ) ) Plaintiff, ) ) v. ) Court No. 07-90C ) (Judge Emily C. Hewitt) UNITED STATES OF AMERICA, ) ) Defendant. ) ____________________________________) DEFENDANT'S UNOPPOSED MOTION FOR LEAVE TO FILE ADMINISTRATIVE RECORD ON CD-ROM AND TO WAIVE PAPER COPY Defendant, the United States, respectfully requests leave to file the administrative record utilizing a CD-ROM. This case is designated for electronic filing using the Court's CM/ECF system. The administrative record in this case will exceed the two megabyte size limitation applicable to electronic files, Rules of the United States Court of Federal Claims ("RCFC") General Order 42A ¶ 4, and the 50-page limitation requiring printed documents, RCFC General Order 42A ¶ 5. Defendant's counsel has contacted counsel for plaintiff and he consents to this motion. The administrative record consists of a large number of documents. These materials can most efficiently be delivered to the Court and to the parties on a CD-ROM. This method will provide efficient and easy access to the administrative record by the parties and the Court. Filing on CD-ROM also provides the most efficient and secure method for submission of the administrative record under seal.

Case 1:07-cv-00090-ECH

Document 11

Filed 02/14/2007

Page 2 of 3

Because of the portability and ease of manipulation of the documents on a CD-ROM, we also respectfully request that the Court waive the requirement of RCFC General Order 42A ¶ 5 that an additional paper copy be supplied to the Court. For these reasons, defendant respectfully requests that this motion for leave to file on CD-ROM and to waive the additional paper copy be granted. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Acting Director /s/ Donald E. Kinner DONALD E. KINNER Assistant Director /s/ Delisa M. Sánchez DELISA M. SANCHEZ Trial Attorney U.S. Department of Justice Civil Division Commercial Litigation Branch 1100 L St., N.W. ATTN: Classification Unit 8th Floor Washington, D.C. 20530 Telephone: (202) 616-0337 Facsimile: (202) 305-7643 Electronically filed, February 14, 2006 Attorneys for Defendant

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Case 1:07-cv-00090-ECH

Document 11

Filed 02/14/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 14th day of February, 2007, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR LEAVE TO FILE ADMINISTRATIVE RECORD ON CD-ROM AND TO WAIVE PAPER 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. Parties may access this filing through the Court's system.

/s/ Delisa M. Sánchez DELISA M. SANCHEZ