Free Motion to Stay - District Court of Federal Claims - federal

Case 1:02-cv-00796-FMA

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

INFORMATION SYSTEMS & NETWORKS CORPORATION, Plaintiff, v. THE UNITED STATES, Defendant.

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Case No.02-796C (Judge Allegra)

MOTION TO STAY DISCOVERY AND TO APPROVE SUBSEQUENT DISCOVERY SCHEDULE The plaintiff, Information Systems & Networks Corporation ("plaintiff" or "ISN"), by its undersigned attorneys, moves this Honorable Court for a stay of all discovery until such time as ISN's Motion for Partial Summary Judgment ("the Motion") is decided by the Court. In the event the Motion is denied, ISN requests the Court to approve the schedule for completing discovery as set forth herein. The grounds of this Motion are as follows: 1. On November 12, 2003, this Court granted an agreed motion for extension

of time to complete discovery, requiring the exchange of expert reports by February 20, 2004 and the completion of all discovery by April 30, 2004 ("the Order"). 2. After the entry of the Order pursuant to Status Reports submitted to the

Court, the parties engaged in settlement negotiations. Because settlement was not accomplished, defendant will now file its Opposition to the Motion by April 30, 2004. ISN will then file its Reply (an extension for this purpose is the subject of a separate motion filed by ISN).

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3.

As a result of the settlement negotiations which resulted in an extension of

the Opposition to the Motion, the dates set forth in the Order became moot. 4. Until such time as the Motion is decided by the Court, ISN requests that

all discovery be stayed. 5. After decision on the Motion, ISN proposes the following schedule to

complete discovery:

(A)

The parties shall exchange expert reports within ninety (90) days

of the entry of the order on the Motion.

(B)

The parties shall complete all discovery, including expert

discovery, within (8) months from the entry of the order on the Motion.

6.
forth herein.

Defendant consents to this Motion and the revised discovery schedule set

WHEREFORE, the plaintiff, Information Systems and Networks Corporation, requests that all discovery be stayed until decision on the Motion for Partial Summary Judgment and if the Motion is denied, discovery shall be completed as outlined herein. Dated: April 1, 2004 Respectfully submitted, SINGER & ASSOCIATES, PC

By:

s/ Norman H. Singer NORMAN H. SINGER, ESQUIRE 10411 Motor City Drive Suite 725 Bethesda, Maryland 20817 T. (301) 469-0400 F. (301) 469-0403 Counsel for the Plaintiff

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CERTIFICATE OF SERVICE I hereby certify that a true copy of the foregoing "Agreed Motion to Stay All Discovery and to Approve Subsequent Discovery Schedule" was delivered via facsimile, this 1st day of April 2004 to: Brent M. McBurney, Esquire Commercial Litigation Branch Civil Division U.S. Department of Justice ATT: Classification Unit 1100 L Street, N.W. 8th Floor Washington, D.C. 20530

_s/ Norman H. Singer________________________ NORMAN H. SINGER, Esquire

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