Free Application for Access to Protected Material - District Court of Federal Claims - federal

Case 1:06-cv-00706-CFL

Document 14-2

Filed 10/30/2006

Page 1 of 2

Exhibit A to Application to Protective Order: Detailed Narrative
a. My position and responsibilities as in-house counsel, including my role in providing advice in procurement-related matters. My position with Cadence is General Counsel. I also maintain responsibilities as Chief Administrative Officer. As General Counsel, I manage all legal and contractual matters, concerning formation, enforcement and dispute resolution of contracts, both prime and sub-tier. As Chief Administrative Officer, I have responsibility for human resource, insurance issues and related administrative functions of the company. With regard to procurement related matters, I am often consulted and I provide advice concerning interpretation of procurement regulations, the interpretation of solicitations requirements and proper methods of responding to solicitation requirements, and all protest issues resulting from solicitations and proposals. I am an owner of Cadence Contract Services, LLC. b. The person(s) to whom I report and their position(s) and responsibilities. I report to the President of the company, Robert Newberry. I also work closely with Scott Doxey, who is the Chief Financial Officer. Robert Newberry is responsible for company operations. He is also involved in the creation of competitive proposals, with oversight of Cadence's Proposal Manager, which is a separate position held by a separate Cadence employee. Robert Newberry is responsible for the development of proposal pricing. Although I do not report to Scott Doxey, I routinely need financial information from him to perform my responsibilities. c. The number of in-house counsel at the office in which I work and their involvement, if any, in competitive decision making and in providing advice in procurement-related matters. There is no other in-house counsel. d. My relationship to the nearest person involved in competitive decision making (both in terms of physical proximity and corporate structure); and The President is ultimately responsible for competitive decision making. I report to him. He is in the office next to mine. e. Measures taken to isolate me from competitive decision making and to protect against the inadvertent disclosure of protected information to persons not admitted under the Protective Order. The following measures will protect against inadvertent disclosure of protected information:

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Case 1:06-cv-00706-CFL

Document 14-2

Filed 10/30/2006

Page 2 of 2

(1) All protected information is being provided in a scanned electronic format, on a CD, thereby reducing the possibility of inadvertently viewing a paper copy; (2) All protected material (whether hard copy or electronic CD) will be kept in a locked filing cabinet, the key to which is kept only by me; (3) All electronic data relating to this case is kept on my laptop computer, which is not part of a company network, and is therefore not accessible by persons other than me; and (4) My email resides on a third-party provider's server, is not hosted by a Cadence server, and is therefore not accessible by Cadence personnel. In addition to the above measures, I periodically undertake legal matters from former and new clients, and maintain their legal matters completely separate from matters pertaining to Cadence and my responsibilities for Cadence. This demonstrates an historic ability to separate and maintain legal issues separate from Cadence responsibilities.

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