Haytham: I completely understand the fatigue and think that you should prioritize the trial right now. However, I have a few questions about what Lisa sent: Whereas I think this chart is a start, I do not understand it. Do the dollar amounts on the chart mean that CSSS could be earning upwards of $22Billion, based on the total dollar amount in red on the bottom or would they have only earned a portion of that, which would represent the "set aside"? I am thinking that a company earning $22B would probably not be viewed as a "small business." Also, I don't understand the acronyms. Further, what is the time frame that the chart refers to? What I need is a clear comparison of # and $ amount for contracts for which CSSS was eligible/bid for over the last few years as opposed to what they are eligible for now. We would need the amounts that CSSS would earn on the contracts. I think that perhaps balance sheets would be helpful showing a dip in revenue. It would also be helpful to know the number of employees that are being affected by this loss of VETBIZ listing. What I will do with the pleading is write what I think the judge would need to read to rule on the injunction and then leave blanks for fill in from additional info about CSSS. Maybe it would be better to ask Lisa for more info at that point. WIth all this said, I need to point out that the injunction cases I sent you say that mere economic loss is not considered "irreparable harm" even if it means that a company will go out of business as a result of the behavior that is subject to the injunction. I will keep working on this and try to send you a new draft at the end of the day. Mary Jo From: Haytham Faraj [mailto:haytham@puckettfaraj.com] I cannot recall if I forwarded this to you yesterday. Please incorporate this information into the pleading. I did not get an opportunity to review your work yesterday. We finished late and I was exhausted. I will endeavor to review it today. Thank you for your excellent work. From: Wolford Lisa [mailto:lisa@csss.net] Haytham - This is a listing of opportunities that we did not win/are not eligible to bid as a result of being removed from the CVE database. Let me know if this is detailed enough for you. I can explain some more if you need, just call later after you are done with court today if you have time. I am really looking forward to getting back in the database or having you skinning them alive. Thanks much - Lisa N. Wolford CSSS.NET 402-393-8059w 402-393-1825f SDVOB, 8(a)/SDB & WOB - TS clearances From: Merriman Joel Lisa, Joy checked with some other folks (Jim N., Teri, Rob who checked with Steve S.) and worked with Keith Anstine to put together the attached. To be clear these were pursuits that do not necessarily equate to losses due solely to SDVOSB, but would require SDVOSB validation for award. In at least one instance the government did not award stating lack of listing on the CVE VIP website for CSSS. In a separate instance, one prime (SAIC), cut our share by 50% or roughly $6.4M instead of $12.8M. Please contact Joy for further info as the attached removed internal notes. Thank you. -Joel From: Thiele Joy Joel, Here you go. Thanks. Joy No virus found in this message. |