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

Case 1:02-cv-00796-FMA

Document 77

Filed 03/28/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ ) INFORMATION SYSTEMS & ) NETWORKS CORPORATION, ) ) Plaintiff, ) ) Case No. 02-796C v. ) (Judge Block) ) THE UNITED STATES OF AMERICA, ) ) Defendant, ) __________________________________________) PLAINTIFF'S UNOPPOSED 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. The Opposition is currently due on April 16, 2007. ISN requests an enlargement of time of 25 days, from April 16, 2007 to May 11, 2007. The defendant does not oppose the requested enlargement. The enlargement is necessary because ISN's counsel is required to participate in the following matters during the next thirty (30) days: 1. A motion for reconsideration before the Central Electricity Regulatory

Commission, New Delhi, India in conjunction with India counsel, due April 23, 2007 regarding the particpation of a client in a proposed power project. 2. Opposition to motion for summary judgment in Travelers v. ISN, U.S.D.C.

(Greenbelt, MD) due April 19, 2007. 3. Participation in investigation being conducted by the Navel Criminal

Investigative Services (NCIS) regarding a Navel Officer (within the next 30 days). 1

Case 1:02-cv-00796-FMA

Document 77

Filed 03/28/2007

Page 2 of 2

The motion for summary judgment before the Court is potentially dispositive. ISN needs to devote the proper amount of time in preparing its Opposition and not rely on a submittal which properly addresses all of the issues. Accordingly, additional time is required. 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 May 11, 2007. March 28, 2007 Respectfully submitted, SINGER & ASSOCIATES, P.C.

By:

s/Norman H. Singer_______ NORMAN H. SINGER, ESQ Singer & Associates, P.C. 10411 Motor City Drive Suite 725 Bethesda, MD 20817 Phone: (301) 469-0400 Fax: (301) 469-0403 Counsel for Plaintiff

CERTIFICATE OF FILING I hereby certify that a true copy of the foregoing "PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE ITS OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT" was filed electronically this 28th day of March, 2007, and served via email on counsel for defendant by virtue of electronic filing.

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

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