Free Motion to Supplement the Administrative Record - District Court of Federal Claims - federal

Case 1:07-cv-00612-NBF

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Filed 08/31/2007

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IN THE UNITED STATESCOURT OF FEDERALCLATMS BID PROTEST

CWTIALEXANDER TRAVEL, LTD, and CWTIEL SOL TRAVEL, INC., Plaintiffs,
v.

1 1 1 1 1 1 1 1 1 1

Case No. 07-612 Judge Nancy B. Firestone

THE UNITED STATES, Defendant.

PLAINTIFF'S MOTION TO SUPPLEMENT THE ADMINISTRATIVE RECORD
Pursuant to United States Court of Federal Claims Rule ("RCFC") 52.l(b), Plaintiffs CWTIAlexander Travel, LTD ("Alexander Travel"), and CWTEI Sol Travel, Inc. ("El Sol"), hereby move to include in the Administrative Record information regarding the deliberations, evaluations, decisions, and justifications prepared by or for the United States Army (the "Army," the "Agency," or the "Government"), and all communications between the Government and contractors regarding the delay in commencing performance or extending the total contract period and consequences thereof, of the following Government travel service contracts: (a) Contract W91QUZ-05-C-0005 issued to AirTrak Travel Systems, Inc. (the "AirTrak contract"); (b) Contract W91QUZ-05-C-0006 issued to WingGate Travel for Travel Area 101 (the "WingGate 101 contract"); (c) Contract W91QUZ-05-C-0007 issued to The Alamo Travel Group for Travel Area 102 (the "Alamo 102 contract");

Case 1:07-cv-00612-NBF

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Filed 08/31/2007

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(d) Contract W91QUZ-05-C-0009 issued to The Alamo Travel Group for Travel Area 104 (the "Alamo 104 contract"); and (e) Contract W91QUZ-05-C-0010 issued to WingGate Travel for Travel Area 105 (the "WingGate 105 contract"). Additionally, Plaintiffs move to include in the Administrative Record information regarding the administration under United States Air Force Solicitation W91 QUZ-04b

0003 of contracts awarded to AirTrak, WingGate, and Alamo. Specifically, Alexander Travel and El Sol seek the following documents, most of which Plaintiffs' counsel had sought unsuccessfully from the Government by an earlier request: (a) All communications or documents (including e-mails) reflecting communications, either internal to the Government or between the Government and any of the three awardees or a representative of them, since the date of the contract awards through today regarding:
1.

11.

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iii. iv. v. vi. vii. viii. ix.

Commencement/delay of contract performance; Potential or actual extension of the contract period, including options; Any change or adjustment to locations requiring travel service; Any change or adjustment to workload requirements at any location; Any reference to use of the Defense Travel System ("DTS") in connection with Military Entrance Processing Stations ("MEPS") travel services; Potential or actual price adjustments; Potential or actual equitable adjustments; Change or potential change in staffing or resources provided by awardees to perform the contracts; and Potential or executed contract modifications.

(b) All communications between the Government and AirTrak. Alamo. or WineGate regarding proposed or actual equitable adjustments to prices, or proposed or executed contract modifications under contracts awarded in early 2005 to provide travel service to various Air Force bases under Solicitation W~IQUZ-04-0003. Plaintiffs respectfully request that the Court grant their Motion.

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Case 1:07-cv-00612-NBF

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Dated: August 3 1,2007

Respectfully submitted,

IS/ Lars E. Anderson Lars E. Anderson VENABLE LLP 8010 Towers Crescent Drive, Suite 300 Vienna, Virginia 22 182 (703) 760- 1600 (Telephone) (703) 821-8949 (Facsimile) Attorney of Record

Of Counsel:

Peter A. Riesen Keir X. Bancrofl Patrick R. Quigley VENABLE LLP 8010 Towers Crescent Drive, Suite 300 Vienna, Virginia 22 182 (703) 760-1600 (Telephone) (703) 821-8949 (Facsimile)