Payne Hackenbracht & Sullivan
Lack of Cooperation
To establish a violation of the duty to cooperate, a contractor must prove a Government action was necessary for the contractor to perform and that the Government unreasonably failed or refused to take the action. Zinco General Contractor, Inc., GSBCA No. 6182, 82-2 BCA p 15,917 (1982); Ben C. Gerwick, Inc. v. United States, 152 Ct.Cl. 69, 77, 285 F.2d 432, 436 (1961).