Notice of Intent to File Petition for Protective Order Regarding Request for Records on ITS Project File Number 4635

Agency:	State Government of Mississippi
State:	Mississippi
Type of Government:	State & Local
NAICS Category:	541512 - Computer Systems Design Services 541519 - Other Computer Related Services 541611 - Administrative Management and General Management Consulting Services
Posted Date:	Jun 16, 2025
Due Date:	Jun 23, 2025
Solicitation No:	1601-25-R-RFIN-00073
Original Source:	Please Login to View Page
Contact information:	Please Login to View Page
Bid Documents:	Please Login to View Page

Procurement Details

Smart Number	1601-25-R-RFIN-00073	Advertised Date	06/16/2025 12:00 PM
RFx #	3150006370	Submission Date	06/23/2025 3:00 PM
RFx Status	Open	Major Procurement Category	INFORMATION TECHNOLOGY (IT)
RFx Opening Date	06/23/2025 3:00 PM	Sub Procurement Category	INTENT TO AWARD NOTICE
RFx Type	Req. for Information
Agency
RFx Description	Protective Order Notice for Vendor Response to RFP 4635.

Contact Information

Name	Valerie Luckett	Email	VALERIE.LUCKETT@ITS.MS.GOV
Phone	6014328218	Fax

RFx Items

PRODUCT CATEGORY	PRODUCT DESCRIPTION
92007	Serv CompSoftMicro

Awarded

VENDOR NAME

VENDOR NUMBER

AWARD DATE

AWARD AMOUNT

FUNDING SOURCE

Bid Attachments

Attachments Deloitte Notice of Intent (Conduent)
Attachments Procurement Opportunity And Public Notification Search URL

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Deloitte LLP

1230 Peachtree St. NE, Suite 3100

Atlanta, GA 30309 USA

Tel: +1 404 631 2774

www.deloitte.com

June 13, 2025

Via Email and Certified Mail

Kim White

ITS Public Records Officer

Mississippi Department of Information Technology Services

3771 Eastwood Drive

Jackson, MS 39211-6381

kim.white@its.ms.gov

Re: Notice of Intent to File Petition for Protective Order Regarding Request for

Records on ITS Project File Number 4635

Dear Ms. White:

Deloitte Consulting LLP (“Deloitte”) has received the June 4, 2025, Third Party

Notification Memorandum from the Mississippi Department of Information Technology Services

(“ITS”). This memorandum notified Deloitte that a third party, Conduent, submitted a public

records request regarding ITS Request for Proposal No. 4635 (the “RFP”), Integrated Disease

Surveillance Platform for the Mississippi State Department of Health (the “Platform”).1 Deloitte

was awarded the contract for this Platform on May 14, 2025 (the “Contract”).

In its public records request, Conduent seeks all bidders’ technical proposals; the

evaluation forms for these technical proposals; references; all bidders’ cost proposals, including

their best and final offers; the evaluation forms for these cost proposals; and the awardee Contract

and any Contract amendments.

In accordance with Miss. Code Ann. § 25-61-9, Deloitte hereby gives notice to ITS, with

a copy to Conduent (as the records requestor), of its intent to seek a protective order from the

Chancery Court of Hinds County, Mississippi, to prevent the disclosure of Deloitte’s confidential

and proprietary information and trade secrets contained in its RFP response and related

submissions to ITS.

This protective order is necessary as Deloitte’s proposal responding to the RFP contains

Deloitte’s trade secrets, confidential commercial, financial information, personal identifying

information, and system security information which are exempt from disclosure under Miss. Code

Ann. §§ 25-61-9(1)(a) and 79-23-1. Specifically, this information includes, among other things,

Deloitte’s technical approach and business plans; the company’s proposed project staffing plans;

1 ITS indicated that the agency received delivery confirmation of this notice on June 9, 2025.

personal information about key Deloitte employees proposed for the project; detailed cost and

pricing data and methodology; non-public information regarding other Deloitte customers’

projects and services; performance history; and internal Deloitte policies and procedures. The

public disclosure of this information would significantly damage Deloitte’s competitive position

and would also substantially interfere with Deloitte’s ongoing business operations and its

negotiations with both existing and potential customers. Moreover, given the confidentiality

considerations regarding the sensitive medical and health data that will be maintained on the

Platform, the public disclosure of any information regarding Deloitte’s proposed data security

methodology and practices could also cause harm to the State and its citizens.2

Pursuant to the ITS Public Records Policy, Deloitte submits this notice and statement of

its reasons for seeking a protective order at least 14 days before Deloitte intends to file its petition

for the protective order. Deloitte will submit its petition within the 21-day statutory window. See

Miss. Code Ann. § 21-61-9(1)(a). However, if the parties wish to discuss appropriate redacts and

withholdings to avoid such litigation, Deloitte is willing to meet and confer.

Thank you for your time and attention to this matter. Should you have any questions

regarding this notice, please contact me at acarlucci@deloitte.com or Brett W. Johnson, Deloitte’s

outside counsel, at bwjohnson@swlaw.com.

Very truly yours,

Deloitte Consulting LLP

Copy to:

Ana Beatriz Quezada J.

Conduent

100 Campus Drive, Ste 200 E

Florham Park, NJ 07932

ana.quezada@conduent.com

foia.requests@conduent.com

Brett Johnson, Snell & Wilmer LLP

bwjohnson@swlaw.com

Amy Carlucci, Associate General Counsel,

Deloitte LLP

2 Conduent also seeks the production of the Contract and any Contract amendments. Deloitte

understands that Mississippi law excludes certain contractual terms in state agency contracts from

being treated as confidential information. See Miss. Code Ann. § 25-61-9(7). However, this

provision does not apply to any portions of a contract that are marked as confidential, which may

be treated as trade secrets or confidential commercial or financial information. Therefore, to the

extent the future Contract includes any such confidential information, Deloitte intends to seek a

protective order to prevent the public disclosure of that information as well.

This page summarizes the opportunity, including an overview and a preview of the attached documents.

* Disclaimer: This website provides information about bids, requests for proposals (RFPs), or requests for qualifications (RFQs) for convenience only and does not serve as an official public notice. Individuals who wish to respond to or inquire about bids, RFPs, or RFQs should contact the relevant government department directly.

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Notice of Intent to File Petition for Protective Order Regarding Request for Records on ITS Project File Number 4635

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