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C Culham

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About C Culham

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  1. More curious to me is what comes next? I have followed with interest but admittedly not a full grasp of the legal back and forth. The rule as I understand had strong implications with regard to the gig economy. With it now withdrawn it appears the head scratching and legal interpretations of independent contractor versus that of employee will continue to be in controversary, especially for FLSA. FLSA has been fairly absent as the basis for court actions of independent contractor/employee for the large gigs such as Uber with matters solved, again as I understand, in private arbitration.
  2. Did not say that did not imply that. I implied - artless, rough and tumble, etc. - or in other words not using the art of the FAR to do it and meet the guiding principles. Splitting a procurement to avoid a threshold? It has already been stated that it is one need. Just exploration!
  3. Me thinks Not...19.502-3 Partial set-asides of contracts other than multiple-award contracts.
  4. The discussion sounds like jerry rigging to me rather than being aligned with the guiding principles of FAR 1.102. Especially where in the FAR provides an avenue - individual deviation FAR 1.403. Otherwise it would seem that Vern Edwards' comment (below) rings true when considering the procedures of FAR FAR Part 10.
  5. @Salus I have read and re-read this thread as it trailed on and one thing keeps popping up for me. Reference to contract awards as compared to a size standard. I also note that you have said you understand receiving more awards than the size standard is okay. Yet your terminology is a little off as size determinations are not based on awards but "receipts". I fully understand you may realize this yet your concern about "awards" and size is not fully aligned with 13 CFR 121. Likewise I understand even "receipts" most likely leads to the same concerns that you have expressed about applic
  6. From history, with no specific reference other that at one time I believe FAA had a policy guidance document that provided for preparation of IAA's. The IAA guidance provided that the IAA is to provide the POP as you note along with funding code citations of the other agency inclusive of the expiration of the funding source. This said "I have been told" suggests that there is not language in the IAA as you have at least noted its stated authority (which by the way makes sense in that it is the FAA authority in long form to enter into IAA's). Yet carrying your other comments forward it
  7. SAM has changed some things that is for sure. You might have already read this but..... If the agency posting the notice has enabled the Interested Vendors List (IVL), a link will be available on the left navigation menu of the notice. You must be logged in to access this feature. Select the link in the navigation menu, then select “Add me to the Interested Vendors List.” To remove yourself from the IVL, follow the same path and select “Remove me from the Interested Vendors List.” When you add your entity to the IVL, the entity details from your account will d
  8. I believe you can easily find it. The greatest is an emotional thing - Magic!
  9. Yep you. A little self control. And your example of horse with attributes solely and rider with "other" was coherent? Not so if it has to be proven by additional facts for context of ranch, team, and a flimsy anecdote.. I am sure glad I did not try to evaluate based of your very first offering - attributes of one thing and oh well "something else" for another. I guess you can deny that everything has attributes then so be it. Yet I sure the heck know that you have at least one!!!!!! You devote time always so it should not be too much of an effort or issue for your pr
  10. How dare you!!!! It is quite honestly a sad state of affairs when you will not accept peer review of your posts but we all have to swallow yours with caustic and implied innuendo! Really and what proof do you have? History proved the one the other would have only been proved if either fact was change! Your anecdotal evidence has limited value when establishing a premise.
  11. I am sorry but I just can't get to your original thought and the further explanation as dipositive example whereby a horse's merits are determine by its attributes but a riders merit has something else. After all you now have thrown in ranch and team as well. Each has characteristics, features, properties, and qualities. If the example was refined to a trained horse, untrained horse, horse for food, show horse, competitive horse for dressage, competitive horse for rodeo then an approach to getting the horse of one of these colors would have its attributes as well. Have a great day!
  12. Now this could lead to a very intense discussion. My attempt is to make it as simple as possible. One could argue based on experiences that the merits of a horse and a rider are both attributes and something else.
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