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

Case 1:07-cv-00582-JFM

Document 8

Filed 08/20/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS Bid Protest INFRASTRUCTURE DEFENSE TECHNOLOGIES, LLC Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-582 (Senior Judge Merow)

DEFENDANT'S UNOPPOSED MOTION FOR LEAVE TO FILE THE ADMINISTRATIVE RECORD ON CD 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 an electronic filing case pursuant to the Court's CM/ECF system. The administrative record in this case will exceed the 2MB size limitation applicable to electronic files and the 50 page limitation applicable to printed documents provided in RCFC General Order 42A I. ¶¶ 4, 5. Defendant has unsuccessfully attempted to reach counsel for plaintiff, Infrastructure Defense Technologies, LLP, to ascertain whether plaintiff will oppose this motion. The administrative record is a voluminous set of documents and can most efficiently be delivered to the Court and the plaintiff on a CD-Rom. This method will provide efficient and easy access to the record because we can submit the record in searchable format. Furthermore, pursuant to General Order 42A I. ¶ 7, the sealed administrative record may not be filed electronically unless authorized by the Court. Filing by another media provides the most efficient method for submission of the sealed version of the record.

Case 1:07-cv-00582-JFM

Document 8

Filed 08/20/2007

Page 2 of 3

Based upon the portability and ease of manipulation of the documents on a CD-Rom, we also respectfully request that the Court waive the requirement in paragraph 5 of General Order 42A 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

JEANNE E. DAVIDSON Director s/ Brian M. Simkin BRIAN M. SIMKIN Assistant Director s/ David A. Harrington DAVID A. HARRINGTON Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Telephone: (202) 307-0277 Facsimile: (202) 307-0972 August 20, 2007 Attorneys for Defendant

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Case 1:07-cv-00582-JFM

Document 8

Filed 08/20/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on 20th day of August, 2007, a copy of "DEFENDANT'S UNOPPOSED MOTION FOR LEAVE TO FILE THE ADMINISTRATIVE RECORD ON CD 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/ David A. Harrington