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

Case 1:08-cv-00492-TCW

Document 28

Filed 07/17/2008

Page 1 of 3

PROTECTED MATERIAL TO BE DISCLOSED ONLY IN ACCORDANCE WITH U.S. COURT OF FEDERAL CLAIMS PROTECTIVE ORDER

IN THE UNITED STATES COURT OF FEDERAL CLAIMS (BID PROTEST) __________________________________________ ) DELOITTE CONSULTING LLP, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant, ) ) and ) ) GLOBAL COMPUTER ENTERPRISES, INC., ) ) Defendant-Intervenor. ) __________________________________________) DEFENDANT'S UNOPPOSED MOTION FOR LEAVE TO FILE THE ADMINISTRATIVE RECORD ON CD-ROM AND TO WAIVE PAPER COPY Pursuant to Appendix E of the Rules of the United States Court of Federal Claims ("RCFC") and this Court's July 9, 2008, defendant, the United States, respectfully requests leave to file the administrative record utilizing a CD-ROM and that the Court waive the requirement that defendant file a paper copy of the administrative record. This case is designated an electronic filing case pursuant to the Court's CM/ECF system. Our administrative record in this case will exceed the four megabyte ("MB") size limitation of electronic files and the 50-page limitation of printed documents provided in RCFC Appendix E and RCFC 5.4. The other parties do not oppose this motion. The administrative record consists of several volumes. This voluminous set of

No. 08-492C (Judge Wheeler)

Case 1:08-cv-00492-TCW

Document 28

Filed 07/17/2008

Page 2 of 3

PROTECTED MATERIAL TO BE DISCLOSED ONLY IN ACCORDANCE WITH U.S. COURT OF FEDERAL CLAIMS PROTECTIVE ORDER

documents can most efficiently be delivered to the Court, the plaintiff, and the intervenor upon a CD-ROM. This method will provide efficient and easy access to the record because we can submit the record in searchable format. More important, filing on a CD-ROM provides the most efficient method for submission of the sealed version of the record. We will, however, deliver a paper courtesy copy to the Court pursuant to RCFC Appendix E, paragraph 10, by July 25, 2008. For these reasons, defendant respectfully requests that this unopposed motion for leave to file on CD-ROM and to waive the additional paper copy be granted. Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director s/ Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director s/ Sean B. McNamara SEAN B. McNAMARA Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, NW Washington, D.C. 20530 Tele: (202) 305-7573 July 17, 2008 Attorneys for Defendant

Case 1:08-cv-00492-TCW

Document 28

Filed 07/17/2008

Page 3 of 3

PROTECTED MATERIAL TO BE DISCLOSED ONLY IN ACCORDANCE WITH U.S. COURT OF FEDERAL CLAIMS PROTECTIVE ORDER

CERTIFICATE OF FILING AND SERVICE I hereby certify that on this 17th day of July, 2008, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR LEAVE TO FILE THE 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. I further certify that the 18 day of July, 2008, I will cause to be served by hand delivery copies of a CD-ROM containing the Sealed Administrative Record addressed as follows: William W. Goodrich, Jr. Arent Fox LLP 1050 Connecticut Avenue, N.W. Washington, D.C. 20036-5339 Attorney representing Deloitte Consulting LLP and Jonathan J. Frankel Wilmer Cutler Pickering Hale & Dorr LLP 1875 Pennsylvania Avenue, N.W. Washington, D.C. 20006 Attorney representing Global Computer Enterprises

s/ Sean B. McNamara SEAN B. McNAMARA Trial Attorney Commercial Litigation Branch Civil Division Department of Justice