Free Motion for Judgment on the Administrative Record - District Court of Federal Claims - federal

Case 1:07-cv-00016-LMB

Document 33

Filed 02/14/2007

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REDACTED COPY CERTIFICATE OF FILING I hereby certify that on this 9th day of February 2007, a copy of the foregoing " PLAINTIFF'S MOTION FOR JUDGMENT ON THE ADMINISTRATIVE RECORD " 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 David P. Hendel David P. Hendel

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Case 1:07-cv-00016-LMB

Document 33

Filed 02/14/2007

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REDACTED COPY 1. A Declaration that the Postal Service's award to SteelCloud, and the initial order of 26 units under that contract, was arbitrary, capricious, and otherwise not in accordance with law and direction to the Clerk to enter judgment in favor of Plaintiff; 2. A determination that M&A is entitled to file an application for an award of bid and proposal costs; 3. Such other and further relief as the Court deems necessary or appropriate in the interests of justice. Respectfully Submitted, s/David P. Hendel _______________________________ David P. Hendel Akerman Senterfitt Wickwire Gavin, P.C. 8100 Boone Blvd., Ste. 700 Vienna, Virginia 22182 (703) 790-8750 (703) 448-1767 (Fax) Attorney of Record for M&A Technology, Inc. Of Counsel: J. Michael Littlejohn Claude P. Goddard Pavan Khoobchandani Akerman Senterfitt Wickwire Gavin, P.C. 8100 Boone Blvd., Ste. 700 Vienna, Virginia 22182 (703) 790-8750

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Case 1:07-cv-00016-LMB

Document 33

Filed 02/14/2007

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REDACTED COPY IN THE UNITED STATES COURT OF FEDERAL CLAIMS (PROTECTED/CONFIDENTIAL MATERIAL TO BE DISCLOSED ONLY IN ACCORDANCE WITH U.S. COURT OF FEDERAL CLAIMS PROTECTIVE ORDER) ) ) Plaintiff, ) ) v. ) ) UNITED STATES, ) ) Defendant. ) ___________________________ ) M&A TECHNOLOGY, INC.

BID PROTEST Filed Under Seal Fed. Cl. No. 07-16 (Judge Baskir)

PLAINTIFF'S MOTION FOR JUDGMENT ON THE ADMINISTRATIVE RECORD Pursuant to RCFC 52.1(b), Plaintiff hereby moves for Judgment on the Administrative Record. In accordance with RCFC 52.1(b), Plaintiff is filing contemporaneously in support of this motion a Statement of Facts and a memorandum setting forth the factual and legal basis for its motion. As set forth in the Memorandum and Statement of Facts, the Postal Service's award decision to SteelCloud is arbitrary, capricious and in violation of law and regulations. Accordingly, Plaintiff respectfully requests that the Court determine that the award decision is arbitrary and capricious and afford Plaintiff the following relief:
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