Free Cross Motion [Dispositive] - District Court of Federal Claims - federal

Case 1:08-cv-00133-MMS

Document 37

Filed 03/24/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS Bid Protest ) GLOBAL COMPUTER ENTERPRISES, ) INC. ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. )

No. 08-133C (Judge Sweeney)

PLAINTIFF'S CROSS-MOTION FOR JUDGMENT ON THE ADMINISTRATIVE RECORD AND MOTION FOR PERMANENT INJUNCTIVE RELIEF

Pursuant to RCFC 52.1(b), and for the reasons set forth in the accompanying Memorandum (1) In Reply To Defendants' Oppositions To Plaintiff's Motion For Preliminary Injunction And Application For Temporary Restraining Order; (2) In Opposition To Defendants' Motions To Dismiss; (3) In Opposition To Defendants' Motions For Judgment On The Administrative Record; And (4) In Support Of Plaintiff's Cross-Motion For Judgment On The Administrative Record ("Memorandum"), Plaintiff Global Computer Enterprises, Inc. ("GCE") respectfully moves that this Court grant GCE's Cross-Motion For Judgment on the Administrative Record. Pursuant to RCFC 65, for the reasons set forth in the accompanying Memorandum, GCE respectfully moves that this Court grant GCE's Motion for Permanent Injunctive Relief.

Case 1:08-cv-00133-MMS

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Filed 03/24/2008

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GCE has filed this Motion accompanied by a proposed Order addressing the motions made herein and other issues in this Action. Respectfully submitted,

/s/ Jonathan J. Frankel Jonathan J. Frankel Wilmer Cutler Pickering Hale and Dorr LLP 1875 Pennsylvania Ave, NW Washington, D.C. 20006 (202) 663-6113 (tel.) (202) 663-6363 (fax) Counsel of Record for Plaintiff Global Computer Enterprises, Inc.

Of Counsel John P. Janecek Ariel B. Waldman Timothy R. Schnabel Sara K. Kasper Wilmer Cutler Pickering Hale and Dorr LLP 1875 Pennsylvania Ave, NW Washington, D.C. 20006 (202) 663-6000 (tel.) (202) 663-6363 (fax)

Dated: March 24, 2008

Case 1:08-cv-00133-MMS

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Filed 03/24/2008

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CERTIFICATE OF SERVICE I hereby certify that on this 24th day of March, 2008, a copy of the foregoing was filed through the Court's Electronic Case Filing system, and was therefore served on counsel of record pursuant to Court of Federal Claims Rules Appendix E, Paragraph 12(c). /s/ Jonathan J. Frankel Jonathan J. Frankel Wilmer Cutler Pickering Hale and Dorr LLP 1875 Pennsylvania Ave, NW Washington, D.C. 20006 (202) 663-6113 (tel.) (202) 663-6363 (fax) Counsel of Record for Plaintiff Global Computer Enterprises, Inc. Dated: March 24, 2008