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Amy Laderberg O'Sullivan

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Amy Laderberg O'Sullivan is a partner in the firm's Washington, D.C. office, a member of the Steering Committee for the firm's Government Contracts Group, and former chair of the firm’s Diversity Council. Her practice involves a mix of litigation, transactional work, investigations, and counseling for corporate clients of all sizes and levels of experience as government contractors. On the litigation side, she has represented corporate clients in bid protests (agency level, GAO, ODRA, Court of Federal Claims, Court of Appeals for the Federal Circuit, as well as state and local bid protests in numerous jurisdictions), size and status protests before the U.S. Small Business Administration, claims litigation before the various Boards of Contract Appeals, Defense Base Act claims litigation at the Administrative Law Judge and Benefits Review Board levels, civil and criminal investigations, and she has been involved in complex commercial litigation.

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On May 29, 2025, the Department of Labor (DOL) announced that it will begin a “phased pause in operations at contractor-operated Job Corps centers nationwide.” The pause is anticipated to occur within a month—by June 30, 2025. To effectuate this pause, DOL has suspended operations at approximately one hundred contractor-operated Job Corps centers.  DOL instructed centers to suspend program activities, transition students home, and implement other transition plans. According to DOL’s Frequently Asked Questions, the Department anticipates that  students will transition to “state and local workforce partners” including American Job Centers and the Labor Exchange system in their home state.Continue Reading Job Corps Centers: Widespread Contract Terminations due to Agency’s “Pause”

On May 7, 2025, GAO issued a decision in Raven Investigations & Security Consulting, LLC, B-423447, warning the bid protest bar that artificial intelligence (“AI”)-based tools utilized without proper oversight may result in severe consequences, including dismissal of the protest and sanctions.Continue Reading “Confirm You’re Not a Robot”: AI-Written Briefs Could Lead to Sanctions

On May 12, 2025, the U.S. Small Business Administration (SBA) announced that it is holding a tribal consultation meeting and requesting comments and input on topics relating to the 8(a) and mentor-protégé programs. The tribal consultation will be held on June 13, 2025 in Anchorage, Alaska, and SBA is anticipating that the meeting will cover a range of topics relevant to 8(a) and mentor-protégé program participants.Continue Reading Tribal Consultation Meeting for 8(a) Business Development and Mentor-Protégé Programs Provides Insight Into SBA Priorities Under the New Administration

United States Attorneys’ Offices recently announced a number of False Claims Act (FCA) settlements arising out of the Paycheck Protection Program (PPP). These settlements reveal several trends that PPP loan recipients should be aware of.Continue Reading Recent Deluge of Paycheck Protection Program False Claims Act Settlements

On February 24, 2025, the Small Business Administration (SBA) issued a “Day One” memo outlining SBA Administrator Kelly Loeffler’s priorities. 

The “Day One” memo highlights SBA’s focus on the Trump administration initiatives—including implementing President Trump’s executive orders; mandating that all non-exempt employees return to full-time, in-office work; and working closely with the Department of Government Efficiency (DOGE) in accomplishing accountability, transparency, and efficiency.  SBA will relocate regional offices “currently based in sanctuary cities” to what it characterizes as “less costly, more accessible locations in communities that comply with federal immigration law.”Continue Reading SBA Issues “Day One” Memo – with a Particular Emphasis on Rooting out Fraud

On December 18, 2024, the U.S. Attorney’s Office for the Western District of Texas announced a $680,000 False Claims Act (FCA) settlement with Lafayette RE Management LLC (Lafayette) in connection with the real estate investment firm’s receipt of a Paycheck Protection Program (PPP) loan at the height of the pandemic.  Crowell has previously reported on DOJ’s steady pursuit of PPP cases which have resulted in FCA settlements based on issues such as affiliation (discussed here) and ineligibility under the program’s rules (discussed here), but the Lafayette settlement is the first time that the government has intervened in a case based on the economic necessity certification that all PPP borrowers had to make on the initial loan application.  Continue Reading DOJ Settles PPP Case Based on Economic Necessity Certification

Late on the night of January 21, 2025, President Trump signed the “Ending Illegal Discrimination And Restoring Merit-Based Opportunity” Executive Order (the “EO”). This EO, like a number of the executive orders issued on his first day in office, took aim at Diversity, Equity, and Inclusion (“DEI”) programs by, among other things, broadly directing executive agencies and departments to terminate all “discriminatory and illegal preferences, mandates, policies, programs, activities, guidance, regulations, enforcement actions, consent orders, and requirements;” curtailing the Office of Federal Contract Compliance Programs’ (OFCCP) operational authority and directing agencies to scrutinize the DEI practices of private sector employers. Additionally, this language raises questions about the future and status of certain programs, preferences, and set-aside procurements administered by the U.S. Small Business Administration, U.S. Department of Transportation, and other agencies. Continue Reading Trump Targets OFCCP, DEI in Executive Order

The term “bid protest” typically calls to mind challenges to an agency’s award of a contract.  But two recent GAO sustain decisions—Wilson 5 Service Company, Inc., B-422670, Sept. 25, 2024, 2024 CPD ¶ 230 and MAXIMUS Federal Services, Inc., B-422676, Sept. 16, 2024, 2024 CPD ¶ 222—highlight another impactful tool for protecting a contractor’s ability to compete fairly: pre-award challenges to ambiguous or unreasonably restrictive solicitation terms.Continue Reading Bid Protest: Unreasonable and Ambiguous Solicitation Terms Sink Procurements

For the first time in nearly a decade, GAO in Knudsen Systems, Inc. sustained a protest challenging an agency’s decision to set aside a procurement for small businesses.  The decision involves the so-called “Rule of Two”:  under FAR 19.502-2(b), agencies must set aside for small businesses a procurement with an anticipated dollar value of more than $150,000 where the agency’s market research demonstrates there is a reasonable expectation at least two responsible small business offerors can meet the agency’s requirements at a fair market price.Continue Reading “Et ‘two,’ GAO?”:Recent Sustain on the Rule of Two Reminds Agencies of the Importance of Accurate Market Research

  • Key takeaway #1Protests of an agency’s actions during corrective action can raise tricky timeliness issues—if the protest could be construed as challenging the ground rules of the procurement, the protest may be subject to the pre-award timeliness rules. But protests that do not challenge the procurement ground rules, and instead
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