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

Case 1:08-cv-00487-SGB

Document 19

Filed 07/11/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

AXIOM RESOURCE MANAGEMENT, Plaintiff, v. THE UNITED STATES Defendant.

INe.

CoFC No. 08-487C BID PROTEST (JUDGE BRADEN)

PLAINTIFF'S SECOND MOTION TO SUPPLEMENT THE RECORD AND RE~UEST FOR EXPEDITED CONSIDERATION COMES NOW Plaintiff Axiom Resource Management, Inc. ("Axiom"), by Second Motion to Supplement the in Support of herewith, the

and through undersigned counsel, and hereby files Record Axiom's this matter. As more

described in the Memorandum

Second Motion to Supplement the Record, filed concurrently

Court should permit Axiom to supplement the record with the enclosed Notice of Award under the TRICARE called Evaluation, Analysis, and Management Support Program

("TEAMS"),

TPOD/OGC procurement, to Lockheed Martin ("LM") of the

work currently being performed by LM which was the subject of prior litigation before the Court. Axiom Resource Management, Inc. v. United States, 80 Fed. Cl. 530 (2008). Axiom requests for the Court to relief because the Plaintiff believes that this document is necessary a complete understanding of issues in dispute in this matter and

it is a relevant part of the record

Case 1:08-cv-00487-SGB

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Filed 07/11/2008

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Request for E~ress The Court's rules permit

Consideration

judge to set an expedited briefing schedule in order

to resolve motions submitted by the parties. _Se_e CFC 7.2(a). Given the Government's R previously expressed mtl~nt:Lon to later than July 1 a contract the TPOD/OGC procurement no

2008, adherence to the Court's nOrlnal briefing schedule would extend beyond the date of the actual

the resolution of Axiom 's present motion even contract award matter. negating

effective relief that the Court may render in this the Court order that this motion be

Therefore, Axiom respectfully requests

resolved as soon as possible. WHEREFORE Plaintiff respectfully requests that the Court Issue an order

supplementing the record with the enclosed Notice of Award.

Respectfully

Date:

By: s . DeISm"do, Esq. s Legal, LLC 55 Center St. Suite 307 Manassas, VA 20110 (703) 368-8770 fax (703) 368-8772 Counsel for Plaintiff Axiom Resource Management, Inc.

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Case 1:08-cv-00487-SGB

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Filed 07/11/2008

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CERTIFICATE

OF SERVICE

I hereby certifY on this 11th day of July 2008, a copy of the foregoing Plaintiff's Second Motion to Supplement the Record was served by electronic mail on: Counsel for the United States John Todor, Esq., United States Department of Justice, Commercial Litigation Branch, 1100 L Street, N.W., Room 8032, Washington, DC 20530; and Counsel Lockheed Martin, Marcia Madsen, LLP, 1909 K St., NW, Washington, DC 20006.

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