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The OCI mitigation arrangements in those protests do not materially differ from the arrangement here.
He had no intention of giving up whatever it was that he knew — a string of numbers; coordinates, I believe — unless the man he called “Mr.
Cooper” wished to pay for them, or so he intimated; I think Ray has no intention of giving Dirty Cooper he wants.
The identification of conflicts of interest is a fact-specific inquiry that requires the exercise of considerable discretion.
Therefore, the record shows that the contracting officer concluded that the program manager should have been recused from acquisition-related activities well before reviewing the contents of the program managers ND/CI statement.