Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:04-cv-00632-LJB

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

) ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES OF AMERICA, ) ) Defendant. )

INFORMATION SYSTEMS & NETWORKS CORPORATION,

No. 04-632C (Judge Bush)

PLAINTIFF'S CONSENT MOTION FOR ENLARGEMENT OF TIME TO FILE ITS OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT Plaintiff, Information Systems & Networks Corporation ("plaintiff or ISN"), by its undersigned attorneys, moves this Honorable Court for an extension of the filing date for Plaintiff's Opposition to Defendant's Motion For Summary Judgment. ISN requests an enlargement of time of 52 days, The defendant consents

from July 27 to September 17, 2004. to the requested enlargement.

The enlargement is necessary for three reasons: 1. The principals of ISN, including its president and CEO, will be unavailable for a significant portion of July and August due to vacation and business travel. Their input and availability is necessary

in preparing the opposition. 2. ISN's counsel is engaged in other matters requiring extensive time, including a discovery cut-off of August 13, 2004 in a pending federal case, filing of an appellee's brief in an appeal from the Maryland State Board of Contract Appeals,

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and the filing of a reply to an opposition to a motion for summary judgment pending in this Court. 3. ISN's counsel is on vacation during a portion of the month of August. WHEREFORE, for the reasons stated, Information Systems & Networks Corporation requests an enlargement of the time for it to file its Opposition to Defendant's Motion for Summary Judgment, up to and including September 17, 2004. Dated: July 14, 2004 Respectfully submitted, SINGER & ASSOCIATES, PC

By:

_s/ Norman H. Singer_________ NORMAN H. SINGER, Esquire 10411 Motor City Drive Suite 725 Bethesda, Maryland 20817 Tel. (301) 469-0400 Fax (301) 469-0403 Counsel for Plaintiff

CERTIFICATE OF SERVICE I hereby certify that a true copy of the foregoing "PLAINTIFF'S CONSENT MOTION FOR ENLARGEMENT OF TIME TO FILE ITS OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT" was filed electronically this 14th day of July, 2004, and served via email on counsel for defendant by virtue of electronic filing.

s/ Norman H. Singer_______ NORMAN H. SINGER, Esquire

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