ARMED SERVICES BOARD OF CONTRACT APPEALS

OPINION BY ADMINISTRATIVE JUDGE SWEET

ON THE PARTIES’ CROSS

- MOTIONS FOR SUMMARY JUDGMENT

In this appeal, appellant ServeFed, Inc. (ServeFed) challenges a United States Army ( government) performance evaluation that assigned ServeFed an U nsatisfactory Q uality rating and an U nsatisfactory Schedule r ating. ServeFed moves for summary judgment, and the government cross

- move s for summary judgment. Because there are genuine issues of material fact regarding whether that evaluation violated the applicable regulations and was fair and accurate, we deny the motion s.

STATEMENT OF FACTS (SOF) FOR PURPOSES OF THE MOTION

I. Contract

1. On March 19, 20 19 , the government and ServeFed executed contract W81K00

- 19 -P- 0137 (Contract) for healthcare staffing services at Fort Hood (now

Fort Cavazos) , Texas (R4, tab 1 at 1

- 45, 80 ).

2. Acceptable measures are defined under the Contract as including :

Fill rate

- 95%; employee turnover rate

- less than 25% per

year , substantiated patient complaints

- max 2 per year, per provider; no provider initiated cancellation of treatments except as medically required by patient, or provider illness or emergency leave (and approved by government supervisor or designee).

. . . Other performance evaluation Appeal of

- ) ) ServeFed, Inc. ) ASBCA No. 63290 )

Under Contract No. W81K00

- 19

- P

- 0137 )

APPEARANCE FOR THE APPELLANT: Edward J. Tolchin, Esq. Offit Kuman, PA Bethesda, MD

APPEARANCES FOR THE GOVERNMENT: Andrew J. Smith , Esq. Acting Army Chief Trial Attorney LTC Michael R. Tregle, Jr., JA

Trial Attorney2 factors will be monitored that are not qualified by numerical measures which include: contractor provid ing personnel exceeding the minimum qualification standards; timely patient follow

- up when necessary; patient customer service comments; provider and contractor relationship

with hospital staff/government contracting personnel; compliance with all hospital policies and procedures.

(R4, tab 1 at 80

- 81 (emphasis added) )

II. The Federal Acquisition Regulation

3. At the time of contract award and performance, the Federal Acquisition Regulation (FAR) provide d that agencies should complete a Contractor Performance Assessment Reporting System evaluation ( evaluation ). 48 C.F.R. § 42.1503. The

evaluation criteria included : (1) technical (quality of product or service); (2) cost

control for contracts other than firm -f ixed

- price contracts; (3) schedule and timeliness; (4) management or business relations; (5) small business subcontracting; and (6) other factors, as applicable. Id . § 42.1503(b)(2).

4. The Federal Acquisition Regulation define d the relevant r atings fo r each

criteria as follows:

Rating Definition Note (b) Very Good Performance meets contractual requirements and

exceeds some to the

Government’s benefit. The Contractual performance of

the element or sub

- element being evaluated was accomplished with some minor problems for which corrective actions taken by the

contract or were effective. To justify a Very Good rating, identify a significant event and

state how it was a benefit to the

Government. There should have been no significant weaknesses

identified.

(c) Satisfactory Performance meets contractual requirements. Th e contractual performance of the

element or sub

- element contains some minor problems

for which corrective actions taken by the contractor appear or were satisfactory. To justify a Satisfactory rating, there should have been only minor problems, or major

pr oblems the contractor recovered from without impact to the

contract/order. There should have been NO significant weaknesses

identified.

. . .3 (d) Marginal Performance does not meet

some contractual requirements. The contractual performance of the element or

sub

- element being evaluated reflects a serious problem for

which the contractor has not yet identified corrective

actions. The contractor’s proposed actions appear only marginally effective or were not fully implemented. To justify Marginal performan ce, identify a significant event in each category that the contractor had trouble overcoming and state how it impacted the Government. A Marginal rating should be supported by referencing the management tool that notified the

contractor of the contractual deficiency (e.g., management, quality, safety, or environmental deficiency report or letter). (e) Unsatisfactory Performance does not meet most contractual requirements and recovery is not likely in a timely manner. The

contractual performance of the

element or sub

- element contains a serious problem(s)

for which the contractor’s corrective actions appear or

were ineffective. To justify an Unsatisfactory rating, identify multiple significant events in each category

that the contractor had trouble overcoming and state how it impacted the Government. A

s ingular problem, however, could be of such serious magnitude that

it alone constitutes an unsatisfactory rating. An Unsatisfactory rating should be supported by referencing the

manageme nt tools used to notify

the contractor of the contractual deficiencies (e.g., management, quality, safety, or environmental deficiency reports, or letters).

48 C.F.R. § 42.1503, Table 42 -1 (emphasis added)

.

III. The Evaluation s

5. A Contractor Performance Report Sheet (Report Sheet) used by the

government to evaluate ServeFed’s performance of the contract stated that:

Schedule Performance is defined as the reliability and timeliness of the contractor assessed against the completion of contract and task order dates established for delivery of services and administrative requirements. [Contracting o fficer’s r epresentatives] will consider fill rates, completion of privileging/credentialing packages,4 and any other activities required for schedule perform ance. The fill rate percentage is calculated by dividing the total hours worked by the total hours ordered.

( App. s upp. R4, tab 20 at 1) The Report Sheet also stated that:

Quality of service s will be scored by assessing the contractor’s conformance to the contract requirements, performance work statement, and standards of quality . . .

, and turnover rate. An indicator of quality is the turnover rate of [healthcare providers] performing under the contract. When stated in the contract/task order, the [ c ontracting o fficer ’s r epresentative] will consider turnover

rate. Turnover rate is defined as the number of times the Contractor must replace individual full

- time contract [ healthcare providers]. . . . Minimum acceptable turnover

rates will be identified.

( Id .) Finally, the Report Sheet contained the following table for the relevant ratings :

Rating Range Description Very Good (81

- 90) Performance meets contractual requirements and exceeds

some to the Government’s benefit. The contractual performance of the element being assessed was accomplished with some minor problems for which corrective actions taken by the contractor were effective. Satisfactory (71

- 80) Perfo rmance meets the contractual requirements. The contractual performance of the element being assessed contains some minor problems for which corrective actions taken by the contractor appear or were satisfactory. Marginal (61

- 70) Performance does not meet some contractual requirements. The contractual performance of the element being assessed reflects a serious problem for which the contractor has not yet identified corrective actions. The contractor’s proposed actions appear only marginally effective or were not fully implemented. Unsatisfactory (Less than 61) Performance does not meet most contractual requirements and recovery is not likely in a timely manner. The contractual performance of the element contains serious problem(s) for which the contrac tor’s corrective action appear or were ineffective.

( Id . at 3)5 6. The c ontracting o fficer’s deposition testimony is unclear about her understanding of the meaning of the percentage s in the Report Sheet table’s range

column. At one point, t he c ontracting o fficer suggested that she understood that the percentage s in the Report Sheet’s range column equa led the fill and turnover

rate s by giving the following answer to the following question:

Q: Okay. But the n you just took the 53 [percent turnover rate] and you plugged it into less than 61. Correct? Is that what happened?

A: Yes.

(Johnson d epo. at 30 ) However, the c ontracting o fficer proceeded to suggest

that she did not understand what the percentage s in the Report Sheet’s range

column meant by giving the following answer to the following question:

Q: So what would I have gotten [if the turnover rate was 17 percent]? . . . [ S]till unsatisfactory?

A: That shouldn’t have been unsatisfactory, no.

Q: So how do you do it? . . . [O]r you just don’t know. If you don’t know that’s a

—

A: Yea h , the first is you definitely looking at that. But

yea h

, definitely if [the turnover r ate] was 17 [percent the

contractor ] wouldn’ t have gotten unsatisfactory.

Q: But you just don’t know how that’s calculated though

—

A: Right

.

( I

d . at 31

- 32)

7. In earlier evaluation s than the one challenged here

— namely for the period between April 1, 2019 and September 30, 2019 (2019 Evaluation)

— the government assigned a Satisfactory Quality r ating and a Satisfactory Schedule r ating, noting a fill

rate of 50 % (R4, tab 10 at 1).

8. I n another earlier evaluation than the one challenged here

— namely for the period between October 1, 2019 and September 30, 2020 (2020 Evaluation)

— the6 government assigned a Satisfactory Quality rating and a Marginal Schedule rating

. Due to information rece ived from the c ontracting o fficer ’s r epresentative and the fact

that the clinic had been closed for approximately two to three months as a result of the

COVID

- 19 pandemic, the government changed the 2020 Schedule rating to Satisfactory. (GASUMF ¶ 8; ARGASUMF ¶ 8) * The amended 2020 Evaluation

stated that the “[v]endor’s fill rate was 57%. Although the vendor fill

- rate is unsatisfactory per the [Report Sheet] , all other administrative requirements were

adhered to 100% of the time.” ( R4

, tab 26 at 2 ) The 2020 Evaluation also not ed that

there were 6 turnovers ( id. )

.

9. The statement that the clinic was closed for several months due to the

COVID

- 19 pandemic raises a genuine issue of material fact as to how much of the fill

rate and turnover rate de ficiencies in the 2019 and 2020 Evaluations were attributable

to ServeFed , and about the government’s reasons for those earlier evaluations ( R4, tab

10 at 1

, tab 26 at 2; GASUMF ¶ 8; ARGASUMF ¶ 8 ).

10. On November 30 , 2021, the government issued a n evaluation for the period between October 1, 2020 and September 30, 2021

— which is the evaluation ServeFed challenges in this appeal (Challenged Evaluation). The Challenged Evaluation assigned ServeFed an Unsatisfactory Schedule R ating because:

Vendors fill rate was 47.18%. The vendor was

unsuccessful in [filling] 8 of 17 positions during this performance period. The [government’s] mission changed and therefore, terminated for convenience 5 positions. The 3 remaining vacancies still remained unfilled. Complete privileging packets were submitted timely and accurately

with communication with the vendor. Invoices were received and certified for payment in a timely manner each

month.

KS comments, l etter of concern was sent on May 11, 2021

to th e contractor in reference to the vacant positions on the

contract. Cure Notice was sent to the contractor on September 17, 2021 for continued vacant positions on the

contract.

(R4, tab 47 at 2

- 3 ) The Challenged Evaluation also assigned ServeFed an

Unsat isfactory Quality rating because “[t]he vendor has complied with contract requirements, the performance work statement and standards of quality with the work

* GASUMF refers to the government’s additional statement of undisputed material facts. ARGASUMF refers to ServeFed’s response to the GASUMF.7 staff but the turnover rate during this period of performance is 53% (9 departures)” ( id .). The C hallenged Evaluation further assigned ServeFed a Satisfactory O ther

A reas (Business Relations) rating because “[t]he business relationship between the contractor and their employee [s] was absolutely satisfactory. There were no issues or concerns brought t o my attention or to the attention of the c ontracting o fficer. Company complied with Contractor Manpower Reporting requirements.” ( Id .) The Challenged Evaluation did not assign a c ost rating or a s mall b usiness s ubcontracting

r ating because this was a firm

- fixed

- price contract, and there was no small business subcontracting plan ( id . at 1

- 2). The Challenged Evaluation concluded by recommending against future awards ( id . at 3)

. Neither party has presented any evidence regarding whether any f ailure to support the Unsatisfactory ratings with reference to the management tools used to notify ServeFed of the contractual

deficiencies

— or any failure to indicate the impact on the government

— prejudiced

ServeFed.

IV. Procedural History

11. On December 6, 2021, ServeFed submitted a claim (R4, tab 48). In that claim, ServeFed attached emails that raise a genuine issue of material fact as to

whether at least some of the fill rate deficiencies and turnover rate deficiencies were

attributable to the government ( id

. at 2

- 4, 9

- 10 , 12

- 13, 20 ).

12. On March 3, 2022, the c ontracting o fficer (CO) issued a final decision

, changing the Schedule r ating from Unsatisfactory to Marginal due to the government causing some delays in the security background check process. However

, the contracting officer declined to change the Schedule r ating to Satisfactory . The

c ontracting o fficer’s f inal d ecision also declined to change the Unsatisfactory Quality

r ating. (R4, tab 50 at 4)

13. To date, the c ontracting o fficer has not changed the Schedule r ating (Johnson d epo. at 44

- 45).

DECISION

Neither ServeFed nor the government is e ntitled to summary judgment

.

I. Summary Judgment Standard

We will grant summary judgment only if there is no genuine issue as to any material fact, and the moving party is entitled to judgment as a matter of law. Celotex Corp. v. Catrett , 477 U.S. 317, 322

- 23 (1986). All significant doubt over factual

issues must be resolved in favor of the party opposing summary judgment. Mingus Constructors, Inc. v. United States , 812 F.2d 1387, 1390 (Fed. Cir. 1987). In deciding8 summary judgment motions, we do not resolve controversies, weigh evidence, or make credibility determinations. Anderson v. Liberty Lobby, Inc. , 477 U.S. 242, 255 (1986). Moreover, we draw all reasonable inferences in favor of the non

- movant. Id

. “ A genuine issue of material fact arises when the nonmovant presents sufficient evidence upon which a reasonable fact

- finder, drawing the requisite inferences and applying the applicable evidentiary standard, could decide the issue in favor of the nonmovant. ”

C. Sanchez & Son, Inc. v. United States , 6 F.3d 1539, 1541 (Fed. Cir. 1993).

II. ServeFed is not Entitled to Summary Judgment

ServeFed is not entitled to summary judgment on its appeal regarding the Challenged Evaluation. In issuing a n evaluation, a contracting officer must follow applicable regulations and provide an appellant with a fair and accurate evaluation

. ServeFed, Inc. , ASBCA No. 63290, 23

- 1 BCA ¶ 38,282 at 185,877 (citing PROTEC GmbH, ASBCA No. 61161 et al. , 18

- 1 BCA ¶ 37,064 at 180,420)

. “ Generally, in order for a contractor to have standing to raise a procedural challenge, the contractor must show prejudice. ” PROTEC GmbH , ASBCA No. 61161 et al. , 19

- 1 BCA ¶ 37,362 at 181,684 (citing Todd Constr

, . L. P . v. United States , 656 F.3d 1306, 1315

- 16 (Fed. Cir. 2011); GSC Constr., Inc. , ASBCA No. 58747, 14 -1 BCA ¶ 35,714

at 174,868). As discussed in greater detail below, there are genuine issues of material

fact as to whether the government followed applicable regulations and the Challenged

Evaluation was fair and accurate.

A. There is a Genuine Issue of Material Fact as to Whether the Government Followed Applicable Regulations

There is a genuine issue of material fact as to whether the government followed applicable regulations. ServeFed argues that the government did not follow the Federal Acquisition Regulation because its evaluation factors did not include : (1) technical (quality of product or service); (2) cost control for contracts other than

firm

- fixed

- price contracts; (3) schedule and timeliness; (4) management or business relations; and (5) small business subcontracting . (A pp. mot. at 11

- 12; SOF ¶ 3 ) However, the Report Sheet and the Challenged Evaluation show that the governm ent evaluated the quality of the healthcare staffing service s , the schedule and timeliness,

and the business relations

. (SOF ¶ ¶ 5, 10 ) While the government di d not evaluate cost controls or small business subcontracting, that was because

— as the Challenged Rating

indicate d— this was a firm

- fixed

- price Contract and there was no small business subcontracting

. (SOF ¶ 10 )

Indeed, ServeFed’s real complaint appears to be not so much about the government’s evaluation criteria as it is about the fact that the government relied upon a singular problem within the Schedule c riteria and a singular problem within the Quality c riteria

— namely the purportedly deficient fill and turnover rates9 respectively

— to assign Unsatisfactory r atings. However, the Federal A cquisition Regulation permitted the government to base an Unsatisfactory r ating up on a sing ular problem, stating that “[a] singular problem, however, could be of such serious magnitude that it alone constitutes an unsatisfactory rating

. ” (SOF ¶ 4) ; Odysse y Int’l

, Inc. , ASBCA No. 62085 et al. , 21

- 1 BCA ¶ 37,861 at 183,8 52 (holding that an unsatisfactory rating based upon a singular problem complie d with the Federal Acquisition Regulation ).

ServeFed also argues that the government did not follow the Federal Acquisition Regulation because it did not support the Unsatisfactory r ating s with reference to the management tools used to notify ServeFed of the contractual deficiencies, or indicate the impact on the government (a pp. mot. at 13). T he Federal Acquisition Regulation merely indicate d that an evaluation “should” support an Unsatisfactory r ating with reference to the management tools used to notify the contractor of the contractual deficiencies, ( SOF ¶ 4 ), which renders the phrase permissive instead of mandatory. Khuri v. United States , 154 Ct. Cl. 58, 64 (1961). In
any event , the government supported the Unsatisfactory Schedule r ating with reference to the management tools used to notify ServeFed of the contractual deficiencies by stating that a “[l]etter of concern was sent on May 11, 2021 to the contractor in reference to the vacant positions on the contract. Cure Notice was sent to the contractor on September 17, 2021 for continued vacant positions on the contract.” ( SOF ¶ 10) Whether those management tools to notify ServeFed of the Contract deficiencies addressed the purported turnover rate deficiencies that underpinned the Unsatisfactory Quality rating too

— and whether that was sufficient to support the Unsatisfactory Quality rating with reference to the management tool used to notify

ServeFed of the contractual deficiencies

— raise genuine issues of material fact. Further, there are genuine issues of material fact as to whether any failure to support the Unsatisfactory r ating s with reference to the management tools used to notify

ServeFed of the contractual deficiencies

— or any failure to indicate the impact on the

government

— prejudiced ServeFed

. (SOF ¶ 10 )

Thus, ServeFed has not established as a matter of law that the government failed to follow applicable regulations.

B. There is a Genuine Issue of Material Fact as to Whether the Challenged

Evaluation was Fair and Accurate

There is a genuine issue of material fact as to whether the Challenged

Evaluation was fair and accurate. ServeFed argues that the government improperly evaluated only the fill rate for the Schedule rating and the turnover rate for the Quality

r ating, while the Contract and the Repor t Sheet required the government to evaluate

other criteria too . (A pp. mot . at 8- 10 ; SOF ¶¶ 2, 5 ) However, the government did not only evaluate the fill rate for the Schedule rating; it evaluated other criteria by stating10 that “[c]omplete privileging packets were submitted timely and accurately with

communication with the vendor. Invoices were received and ce rtified for payment in a timely manner each month ” (SOF ¶ 10 ). Similarly, the government did not only

evaluate the turnover rate for the Quality rating ; it evaluated other criteria by stating that “[t]he vendor has complied with contract requirements, the performance work statement and standards of quality with the work staff . . . .” ( id. ).

Again, ServeFed’s real complaint appears to be not so much about t he

government ’s evaluation criteria as it is about the fact that the government relied upon a singular problem within the Quality c riteria and a singular problem within the

Schedule c riteria to assign Unsatisfactory r atings ( a pp. mot. at 11 ). However, as discussed above, the Federal Acquisition Regulation permitted the government to base

an Unsatisfactory r ating upon a singular problem (SOF ¶ 5 ).

ServeFed also appears to argue that the 2019 and 2020 Evaluations establish ed that the Challenged Evaluation was arbitrary because ServeFed received Satisfactory Quality ratings and Satisfa ctory Schedule r atings on the 2019 and 2020 Evaluations

, despite purportedly similar fill and turnover rates ( a pp. mot. at 10 ; app. reply at 19

- 20 ). As an initial matter, the initial 2020 Evaluation assigned a Marginal Schedule rating,

and the final 2020 Evaluation expressly stated that the fill rate was unsatisfactory (SOF ¶ 8 ). In any event, th e fact that ServeFed had different fill and/or turnove r rates during those prior periods raises a genuine issue of material fact as to whether the different ratings for those prior periods establish that the Challenged Evaluation’s

r atings were unfair and inaccurate ( SOF ¶ ¶ 7

- 8 ). Moreover, there are genuine i ssues of material fact as to how much of the fill rate and turnover rate deficiencies in the

2019 and 2020 Evaluations were attributable to ServeFed , or the result of other causes,

such as the COVID

- 19 pandemic (SOF ¶ 9 )

.

ServeFed next argues that the a dmission in the c ontracting o fficer ’ s f inal

d ecision that some of the fill rate deficiency was the government ’s fault renders the Challenged Evaluation’s reliance upon the fill rate deficiency unfair and inaccurate ( a

pp. mot. at 13

- 14). H owever, there are genuine issues of material fact as to how

much of the fill rate deficiency the government caused, and whether the fill rate deficiency attributable to ServeFed met the Contract’s requirements.

S erveFed also argues that the government ha s not changed its Schedule r ating

to a M arginal rating yet, despite the c ontracting o fficer ’s f inal d ecision ’s conclusion

that the Schedule rating should be so changed ( a pp. mot. at 14). However, “[b]ecause we are ‘required to assume that the Government [ will ] carry out the corrective action in good faith’

. . . Chapman Law Firm [ Co. v. Greenleaf Const. Co, Inc. ], 490 F.3d [934,] 940 [Fed. Cir. 2007] (citations omitted), we assume that the government will”

t ake the corrective action it indicated it would take in the c ontracting o fficer ’s f inal11 d ecision. HTA Aviation, LLC , ASBCA No. 57891 et al. , 14

- 1 BCA ¶ 35,556

at 174,240.

ServeFed finally appears to argue that the Challenged Rating was unfair and

inaccurate because the c ontracting o fficer purportedly testified during her deposition

that the percentage in the Report Sheet table’s range equaled the fill and turnover rate s (a

pp. mot. at 6- 7, 14). However, the c ontracting o fficer’s deposition testimony is unclear about her understanding of the meaning of the p ercentage s in the Report Sheet table’s range column (SOF ¶ 6 ). In any event, regardless of the c ontracting o fficer ’s subjective understanding of the meaning of the percentages in the Report Sheet table’s

range column , the Contract required a fil l rate of 95 percent or more, and a turnover rate of less than 25 percent (SOF ¶ 2). However, according to the Challenged

Evaluation , the fill rate was 47.18 percent and the turnover rate was 53 percent (SOF ¶ 10 ). Thus, the Challenged Evaluation raises a genuine issue of material fact as to

whether ServeFed met the Contract’s requirements, and thus whether a M arginal r ating or an Unsatisfactory r ating was unfair or inaccurate

. Further, there are genuine issues

of material fact as to whether any deficient fill and turnover rates were of such a serious magnitude that they alone constituted u nsatisfactory r atings , and thus whether an Unsatisfactory rating in particular was unfair or inaccurate

.

Therefore, ServeFed has failed to show that the Challenged Evaluation was

unfair and inaccurate as a matter of law.

III. The Government is not Entitled to Summary Judgment

Nor is the government entitled to summary judgment. As with its motion to dismiss for failure to state a claim, the government again challenges whether particular turnover and fill rate deficiencies were the fault of ServeFed or the government

. (G ov’t mot. 8, 14) As we held in denying th e motion to dismiss for failure to state a

claim “whether particular turnover and fill rate deficiencies were the fault of ServeFed or the government raises factual issues . . . .” ServeFed, Inc.

, 23

- 1 BCA ¶ 38,282

at 185,878

. Moreover, the re are genuine issues of fact regarding who was at fault for particular turnover and fill rate deficiencies

. (SOF ¶ 11) Thus , the government is not entitled to summary judgment.

The government also argues that any such issues of fact are not material

b ecause the Contract is indifferent with respect to the cause of the deficiencies (g ov’t reply at 3 ). However, notwithstanding the contract’s apparent silence on the manner,

the Evaluation’s ratings are required to be “fair,” and penalizing a contractor fo r occurrences for which it bears no fault or responsibility (depending upon the facts, of course) may well be unfair. Here, there are material facts in dispute about how much responsibility the two parties respectively bear for ServeFed’s filling deficien cies, which precludes us from determining whether the Evaluation was fair or not. Indeed,12 the government appears to recognize that it is unfair to give ServeFed a negative rating for deficiencies beyond its control by arg uing that it gave Satisfactory ratings in earlier

evaluations because the COVID

- 19 pandemic justified turnover and fill rate

deficiencies . (A pp. reply at 13 ) Therefore, the government is not entitled to judgment

as a matter of law.

CONCLUSION

For the reasons discussed above, we deny ServeFed’s motion for summary judgment , and the government’s cross

- motion for summary judgment

.

Dated: November 13 , 2023

JAMES R. SWEET Administrative Judge

Armed Services Board of Contract Appeals

I concur

RICHARD SHACKLEFORD Administrative Judge Acting Chairman

Armed Services Board of Contract Appeals I concur

J. REID PROUTY Administrative Judge

Vice Chairman

Armed Services Board of Contract Appeals13 I certify that the foregoing is a true copy of the Opinion and Decision of the Armed Services Board of Contract Appeals in ASBCA No. 63290

, Appeal of ServeFed,

Inc. , rendered in conformance with the Board’s Charter.

Dated: November 13, 2023

PAULLA K. GATES

- LEWIS Recorder, Armed Services Board of Contract Appeals