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A divided panel of the United States Court of Appeals for the Federal Circuit ruled last week in Bell BCI Co. v. United States, ___ F.3d ___, No. 08-5087, 2009 WL 1796783 (Fed. Cir. June 25, 2009), that boilerplate release language in a bilateral modification barred a contractor's claims for the cumulative and disruptive impact of multiple change orders
