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

Case 1:08-cv-00487-SGB

Document 16

Filed 07/10/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

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

INC.

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

PLAINTIFF'S MOTION TO SUPPLEMENT THE RECORD AND REQQEST FOR EXPEDITED CONSIDERATION COMES NOW Axiom Resource Management, Inc. ("Axiom"), by and

through undersigned counsel, and hereby files this this matter. As more funy described to Supplement

to Supplement the Record in

Memorandum in Support of Axiom's Motion

Record, filed concurrently herewith, the Court should permit Axiom to the deposition the contracting officer here because of the

supplement the record clear gaps

record as filed and the record's failure to completely explain the bases here.

for the Government's

The Court's rules permit

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 intention to a contract under the TPOD/OGC procurement no later than July 14,

2008, adherence to the Court's nOJrm,'llbriefing schedule would extend the resolution of Axiom's present mC)tlcmbeyond the date proposed contract award thereby negating

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Case 1:08-cv-00487-SGB
any effective respectfully requests

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Filed 07/10/2008

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that the Court may

this matter.

Therefore,

Axiom

Comi order that this motion be resolved prior to the award

of any contract under the TPOD/OGC procurement WHEREFORE supplementing the record motion. Plaintiff requests the Court issue an order

deposition described in Axiom's brief supporting this

Respectfully

Date:

By:

:UeTSordo, Esq. us Legal, LLC 9255 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 07/10/2008

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CERTIFICATE I hereby to Supplement on Record was
th

OF SERVICE

10 day of July 2008, a copy of the foregoing Motion electronic on:

Counsel for 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, Mayer Brown, LLP, 1909 K S1., NW, Washington, DC

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