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

Case 1:07-cv-00612-NBF

Document 11

Filed 08/27/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST CWT/ALEXANDER TRAVEL, LTD, and CWT/EL SOL TRAVEL, INC., Plaintiffs v. UNITED STATES OF AMERICA Defendant. 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. In addition, a sealed administrative record may not be filed electronically unless authorized by the Court. RCFC General Order 42A ¶ 7. Counsel for plaintiff has been contacted and will not oppose 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. ) ) ) ) ) ) ) ) ) ) ) )

No. 07-612C (Judge Firestone)

Protected Information to be Disclosed Only in Accordance With U.S. Court of Federal Claims Protective Order

Case 1:07-cv-00612-NBF

Document 11

Filed 08/27/2007

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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 DAVID M. COHEN Director s/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director OF COUNSEL: MAJOR PATRICK GARY GREGORY MORITZ ROBERT DUDLEY Department of the Army 2461 Eisenhower Avenue, Room 984 Alexandria, VA 22331-1700 s/ Melinda D. HartJeffrey S. Pease MELINDA D. HART Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 305-3311 Fax: (202) 514-8640 Attorneys for Defendant

Dated: August 27, 2007

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Case 1:07-cv-00612-NBF

Document 11

Filed 08/27/2007

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CERTIFICATE OF FILING I hereby certify that on this 27th day of August, 2007, a copy of the foregoing "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/Melinda D. Hart