SSJ_Legal_Staffing_Final_Redacted.pdf

Attachment 2 U.S. Customs and Border Protection

Sole Source Justification (SSJ) - RFO Subpart 8.4 and GSAR 538.7104-3 For Orders or BPAs Exceeding the SAT

March 2026

Legal Staffing Support and eDiscovery Services

Date: 9/18/2026 PR Number: 20160566

This acquisition is conducted under the authority of the Multiple-Award Schedule Program, 41 U.S.C.

152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies.1

1. Agency and Contracting Activity.

This Justification and Approval supports the proposed sole source acquisition of Contact Government Services, LLC (CGS) for the U.S. Department of Homeland Security, U.S. Customs and Border Protection (CBP), Office of Chief Counsel (OCC). The DHS CBP Office of Acquisition proposes to award a contract pursuant to the ordering procedures established by General Services Administration (GSA) and intends to proceed with this action in accordance with RFO FAR Subpart 8.4 and GSA Acquisition Regulation (GSAR) Subpart 538.7104-3.

2. Nature and/or description of the action being approved.

CBP intends to place an order on the sole source basis in accordance with GSAR § 538.7104-3 for legal work supporting litigation that entails performing document reviews, reviews and redactions of body worn camera (BWC) footage, cellphone data, and other legal support. These services are related to pending and reasonably anticipated litigation, including litigation challenging CBP’s operational implementation of the Secure America Act’s directives and ability to execute the White House’s priorities.

The proposed contractor for this effort is:

Contact Government Services, LLC (CGS) 1100 13th Street NW, Ste 925 Washington, DC 20005 Unique Entity Identifier (UEI): H2GERTM5PNH3.

1 In this document, citations to RFO Part 8 are citations specifically to Federal Acquisition Regulation (FAR) Class Deviation 25-20 for FAR Part 8, which was issued as part of the Revolutionary FAR Overhaul (RFO) implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

Sole Source Justification (SSJ) - RFO Subpart 8.4 and GSAR 538.7104-3 For Orders or BPAs Exceeding the SAT

March 2026

The order shall be funded with Fiscal Year 2026 one-year operations and support funding. The services will be solicited under Request for Proposal (RFP) 20150566.

3. Description of supplies or services required to meet the agency’s needs.

The requirement is to immediately procure contractor services to assist CBP in conducting document review for high-stakes, high-profile litigation. The document review is large scale and complex. Each matter may involve reviewing hundreds of thousands if not millions of files in a range of formats, including videos from body worn cameras, textual documents, and forensic images, and in multiple review platforms, including Evidence.com, Relativity, RelativityOne, and U.S. Department of Justice’s Civil Online Relativity Application (CORA). The review must be completed within court deadlines that are inflexible and often compressed. Failing to meet these deadlines can lead to dire consequences, including monetary sanctions against the Agency and adverse decisions. As the result of high volumes of ongoing and anticipated litigation, the Agency is in urgent need of support to meet its legal and operational requirements. Accordingly, the requirement is for the immediate support of contractor personnel with specialized expertise to identify, protect, and, where appropriate, redact privileged, sensitive, protected, or otherwise legally restricted information prior to disclosure as well as deliver high-quality outcomes from day one of the engagement.

4. Authority and supporting rationale.

GSAR 538.7104-3(b)(1)(i): The need is of such unusual urgency that following the procedures would result in unacceptable delays in fulfilling this need.

CBP enforcement operations generate substantial volumes of records, video, digital evidence, reports, case materials, and other data that require legal review, organization, redaction, and processing. These materials may be relevant to immigration proceedings, public safety matters, evidentiary determinations, litigation, administrative actions, disclosure obligations, and other law enforcement-related legal functions. CBP has experienced an unanticipated and unexpected rise in discovery and litigation demands that have strained OCC’s resources and ability to meet operational demands in a timely fashion.

Sole Source Justification (SSJ) - RFO Subpart 8.4 and GSAR 538.7104-3 For Orders or BPAs Exceeding the SAT

March 2026

CGS is capable of meeting all CBP’s requirements. CGS has proven its ability to perform large scale document review projects for the Federal government, staffing nearly 100 attorneys to conduct document review for DOJ. CGS’s work with DOJ provides relevant institutional knowledge, familiarity with DOJ-aligned requirements, and continuity of support that directly benefits CBP work performed in support of DOJ and CBP litigation needs. CGS has proven expertise in performing document review on the pertinent platforms, including Evidence.com and RelativityOne. CGS has demonstrated a fulsome understanding of the document review process and their ability to execute it, from determining responsiveness to identifying sensitive information for marking to identifying and redacting privileged information to articulating privilege assertions. CGS has credibly articulated its ability to quickly staff up to 63 personnel with the necessary knowledge and expertise who are capable of successfully clearing a CBP Tier 5 Background Investigation for National Security positions. Additionally, CGS maintains and recruits staff with prior law enforcement experience, bringing specialized knowledge invaluable to the document review process.

This work is mission critical. This work is to defend the Agency in litigation challenging CBP’s legal authorities. If CBP is not able to effectively and efficiently perform this work in accordance with court-ordered deadlines, CBP’s ability to meet its legal and operational requirements will be severely impacted. The consequences would be far-reaching and directly impact the Agency’s ability to carry out its statutory responsibilities.

The results of the market research clearly indicate that CGS is capable of meeting these requirements and meeting the Agency’s urgent needs. This solution will address the immediate, urgent needs, but the Agency will continue to evaluate the marketplace to determine the most appropriate procurement strategy to acquire these services for a longer-term solution.

5. CBP intends to make this justification publicly available in accordance with GSAR 538.7104-3(b)(3).