United States Court of Appeals District of Columbia - Center for ...

Managers to adequately supervise contractor personnel during the period of
this contract” (id. at §C-1.4.1.1); and (2) to ensure adequate supervision of
translators’ performance, L-3 had to assign “at least one staff member with a
security clearance equal to or higher than the linguists working in their
region of responsibility.” Id. at §C-1.4.1.1.4 (emphasis added).
The contract does not distinguish between “operational” and
“administrative” supervision, nor does it limit L-3’s supervisory duties to
“administrative” supervision. RS.112, Appendix C-1, §C-1.1, §C-1.4.1.1,
§C-1.4.1.1.4. No member of the military has ever testified that L-3 was only
required to provide administrative support or “administrative” supervision.
See Rumminger Dep. 62 (Chief Warrant Officer Rumminger, the only
military official to submit a declaration for L-3, testified in deposition that
he knew nothing about L-3’s contract with the military.)
The contract limited the military to using L-3 employees to provide
“interpretation and translation services.” RS.112, Appendix C-1 §C-1.1; see
also id. at §C-5.1; Lagouranis Decl. 17; Mawiri Decl. 9, 14. Unlike
soldiers, corporate employees could and did refuse assignments, and L-3
adjusted its employees’ assignments to keep them satisfied. See Winkler
Dep. 13
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