(1982), provides that all contractor claims must be submitted in writing to the CO in order for a board of contract appeals (BCA) to have jurisdiction. It is undisputed that Malone never submitted a written monetary claim to the CO relating to the default termination. This case, however, concerns a government claim against a contractor. Caselaw supports the proposition that a government decision to terminate a contractor for default is a government claim. Lisbon Contractors, Inc. v. United States, 828 F.2d 759, 764-65 (Fed.Cir.1987) (discussing BCA practice of treating termination for default as government claim, and relying in part on this premise to hold that government bears burden to prove validity of default termination); Z.A.N. Co. v. United States, 6 Cl.Ct. 298, 305-06 (1984) (<HOLDING>); James Reedom, d/b/a J & M Electronic, ASBCA
holding a termination claim is far different from a failure to accommodate claim holding that trial court must make entry of default prior to entry of default judgment and court may not make entry of default when there is no default in law or in fact holding that we cannot avoid ruling on a claim a petitioner has procedurally defaulted if the government has waived the procedural default defense for that claim holding that default termination is government claim holding that termination is an adverse employment action