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Bid Protest Spotlight: Unstated Evaluation Criteria, Record Redactions, Corrective Action

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The December 2025 Bid Protest Spotlight focuses on recent decisions of the Government Accountability Office (GAO) and the Court...

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The December 2025 Bid Protest Spotlight focuses on recent decisions of the Government Accountability Office (GAO) and the Court of Federal Claims.Read the <a href="https://govcon.mofo.com/topics/bid-protest-spotlight-unstated-evaluation-criteria-record-redactions-corrective-action" target="_blank">full blog post</a>.

Bid Protest Spotlight: Unstated Evaluation Criteria, Record Redactions, Corrective Action

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Tori Dalcourt Angle is a senior associate in Morrison Foerster’s Government Contracts and Public Procurement Practice Group and is based in the firm’s Washington, D.C. office.Tori’s practice runs the gamut of litigation and counseling in federal procurement matters, with an emphasis on bid protests, internal and external investigations, False Claims Act matters, contract claims and disputes, and compliance with federal statutes and regulations.Tori regularly represents contractors in pre- and post-award bid protests. She has represented both protesters and awardees in scores of protests before the U.S. Government Accountability Office, the U.S. Court of Federal Claims, and procuring agencies, in acquisitions ranging from small business procurements to multibillion-dollar contracts. Her protests have included both classified and unclassified programs. In addition to prevailing in published decisions, Tori has also secured favorable corrective action on behalf of clients in a wide variety of protests that were resolved without a published decision.Tori has extensive experience conducting investigations with False Claims Act, Anti-Kickback Act, Procurement Integrity Act, and suspension and debarment implications. She has advised clients regarding procurement fraud, anti-corruption, procurement integrity, and defective pricing, and has assisted clients with voluntary and mandatory disclosures under the Federal Acquisition Regulation. In addition, Tori has defended clients in a number of qui tam actions.Tori has experience counseling clients on various compliance and regulatory issues, including Section 889 compliance, revolving door questions, organizational conflicts of interest, and the Truth in Negotiations Act.Tori earned her J.D. with honors and a concentration in Government Procurement Law from the George Washington University Law School, where she was an associate editor of The George Washington Law Review, a Dean’s Fellow in the Legal Research and Writing Program, a member of the Alternative Disputes Resolution Board, and a Murray J. Schooner Government Procurement Law Scholar. She also won multiple academic awards, including the Outstanding Academic Achievement Award from the National Contract Management Association, first place in the 2018 American Bar Association’s Public Contract Law Journal Writing Competition, the 2018 Dentons Government Contracts Moot Court Competition, and Best Brief in the 2017 GW Law School First Year Moot Court Competition.During law school, Tori worked as a law clerk in Morrison Foerster’s Government Contracts practice and participated in the firm’s summer associate program. She also completed an internship in Judge Firestone’s chambers at the U.S. Court of Federal Claims.Prior to law school, Tori interned at the Department of Justice, Consumer Protection Branch, and the National Partnership for Women & Families. She graduated cum laude from American University, where she had dual majors in law & society and history, and a minor in economics.

Victoria Angle

Associate

Government Contracts + Public Procurement

Government Contracts Insights