19GE5026D0076-Sole_Source_Justification.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SECTION 1: IDENTIFICATION OF THE AGENCY AND THE CONTRACTING ACTIVITY

Department of State Contracting Activity ☐ Global Acquisitions

Requiring Activity Overseas Buildings Operations, U.S. Department of State

SECTION 2: NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

Approval is requested to solicit and award on a sole-source basis for a contract to Jamil & Jamil for the supplies and/or services described in Section 3 on behalf of the Requiring Activity.

Previous contract (Contract # 19PK3324D1000 – Embassy Islamabad)

SECTION 3: DESCRIPTION OF SUPPLIES/SERVICES REQUIRED TO MEET THE AGENCY’S

NEEDS

Local legal services are needed to ensure the U.S. Government 's Former Consulate Compound (FCC) known as Frere Compound, in accordance with the terms of an offer received from a competitive marketing initiative, to ensure that the sale is executed in accordance with local law. Ministry of Foreign Affairs of the Islamic Republic of Pakistan has provided a No Objection Certificate, along with the Karachi Metropolitan Corporation. The final No Objection Certificates are in process of being obtained from the Sindh Government before the sale can move to a closing and registration process.

Local legal services are needed to facilitate the US Government’s completion of transaction with various jurisdictions in Pakistan.

The estimated value for the entire period of performance is $500,000.

SECTION 4: IDENTIFICATION OF THE STATUTORY AUTHORITY PERMITTING OTHER

THAN FULL AND OPEN COMPETITION

This statutory authority permitting other than full and open competition is 41 U.S. Code 1901 as implemented by FAR (RFO) 12.102; specifically, this authority permits contracting on a sole-source basis.

SECTION 5: DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE

QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES USE OF THE

AUTHORITY CITED

Since 2003, Jamil & Jamil has been an integral source of legal support and continuity for the Consulate General property. From that time until 2011, the firm filed and obtained replacement title documents and assisted in renewing the expired ground leases. In 2023 the firm was reengaged to facilitate a marketing strategy with

OBO and our broker to obtain a buyer for the property. They then acted as the liaison between the US government and the host government to seek approval to sell from the Ministry of Foreign Affairs of the Islamic Republic of Pakistan and the Karachi Metropolitan Corporation. Jamil & Jamil will continue to assist the USG and the buyer in obtaining the Sindh Government No Objection Certificates, close the sale, and register the title. Given the firm's long-term involvement in supporting the management of this disposal, it has been a source of necessary continuity in legal counsel services and local expertise.

Recent activities related to the complexity of selling properties in this region, particularly with facilitating the necessary legal coordination between the various government agencies, only increases OBO’s need for knowledgeable, immediately available, local legal counsel. Jamil & Jamil have been involved in these matters daily and possess the knowledge and relationships to endure a successful outcome, paving the way for a property settlement. It is critical that their services be available to ensure continuous support of the complex real estate legal matters. The holding cost of this property, related to utilities and guard cost, is nearly $1 million per year and it continues to fall into disrepair. The present offer to buy the property is higher than the market value and would result in no further holding cost, saving the U.S. taxpayers. To remove Jamil & Jamil during this critical period would almost certainly endanger the critical timelines of this highly visible project, while prolonging the holding costs associated with this property.

SECTION 6. DESCRIPTION OF EFFORTS TO ENSURE THAT OFFERS WERE SOLICITED

FROM AS MANY POTENTIAL SOURCES AS IS PRACTICABLE, INCLUDING WHETHER A

NOTICE WAS OR WILL BE PUBLICIZED AS REQUIRED BY FAR SUBPART 5.2 AND, IF NOT,

WHICH EXCEPTION UNDER FAR 5.202 APPLIES

An Intent to Sole Source notice was posted to SAM on June 1, 2026. No responses were received.

SECTION 7. DETERMINATION BY THE CONTRACTING OFFICER THAT THE ANTICIPATED

COST TO THE GOVERNMENT IS FAIR AND REASONABLE

The Contracting Officer has determined the anticipated cost to the Government of the supplies/services covered by this J&A will be fair and reasonable based on price based on prior competitions, market prices and historical prices. By signing the justification, the Contracting Officer makes a determination that the cost to the Government is expected to be fair and reasonable.

SECTION 8. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED (SEE PART 10) AND

THE RESULTS OR A STATEMENT OF THE REASON A MARKET RESEARCH WAS NOT

CONDUCTED

The firm’s long-term involvement in supporting the management of this acquisition has been a source of necessary continuity in legal counsel services and local expertise. Replacing local legal guidance during a critical point in a multi-year long real estate transaction is a decision that will almost certainly cause overall project delays, the cost of which dwarfs the potential (and unlikely) savings from competitively bidding these services at such an inopportune time given the high holding costs of the property.

SECTION 9. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND OPEN

COMPETITION

None.

SECTION 10. LISTING OF SOURCES, IF ANY, THAT EXPRESSED A WRITTEN INTEREST IN

THE ACQUISITION

None received.

SECTION 11. STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO REMOVE

OR OVERCOME ANY BARRIERS TO COMPETITION BEFORE ANY SUBSEQUENT

ACQUISITION FOR THE SUPPLIES OR SERVICES REQUIRED

The services contemplated by this action can almost never be properly replaced in a cost-effective manner.

Replacing local legal guidance during a critical point in a multi-year long real estate transaction is a decision that will almost certainly cause overall project delays, the cost of which dwarfs the potential (and unlikely) savings from competitively bidding these services at such an inopportune time. Further, substitution of new counsel, unfamiliar of the history and participants of a specific transaction, could even endanger the entire viability of that transaction. Finally, the hours required of both new counsel and USG personnel in educating prospective new counsel would be significant.

SECTION 12. CERTIFICATIONS

All reviews and approvals should be completed in the order listed unless otherwise authorized or required.

TECHNICAL AND REQUIREMENTS CERTIFICATION (FAR 6.303-2(b)) I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein, are complete and accurate to the best of my knowledge and belief.

SIGNATURE:

Russell Ottalini April 13th, 2026 Contracting Officer's Representative

CONTRACTING OFFICER CERTIFICATION (FAR 6.303-2(a)(12)) I certify that this submission is accurate to the best of my knowledge, and that it contains complete information necessary to enable other officials to make an informed recommendation for approval or disapproval.

SIGNATURE:

Daniel Jackson Date Contracting Officer

08/20/2026 06:57 GMT

Jackson, Daniel (JacksonDJ@state.gov)

Page intentionally blank.