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

Case 1:02-cv-00796-FMA

Document 28

Filed 04/01/2004

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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)

PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b)(1) of the Rules of the United States Court of Federal Claims ("RCFC"), plaintiff, Information Systems & Networks Corporation ("plaintiff" or "ISN"), by its undersigned attorneys, requests an extension of twenty-four (24) days, up to and including June 4, 2004, in which to file its Reply to defendant's Opposition to Plaintiff's Motion for Partial Summary Judgment ("the Motion"). The Reply is currently due on May 11, 2004. This is ISN's first request for an enlargement of time for this purpose. The enlargement is requested because the undersigned counsel of record for ISN will be in trial before Judge Futey in Information Systems and Networks Corporation v. The United States, Case No.98-663C during the week of May 10, 2004. The matter before Judge Futey is the continuation of a trial which was held the week of November 3, 2003, and then recessed to allow the parties to explore settlement. Because settlement could not be accomplished, the case has been rescheduled for May 11, 12 and 13. As a result, counsel must devote considerable time in the preparation of the resumed trial as well as the trial itself.

Case 1:02-cv-00796-FMA

Document 28

Filed 04/01/2004

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Accordingly, a twenty-four (24) day extension is respectfully requested so as to enable counsel to properly prepare the Reply at the conclusion of the case before Judge Futey. For the foregoing reasons, plaintiff respectfully requests that the Court grant this Unopposed Motion for Enlargement of Time. 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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Case 1:02-cv-00796-FMA

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CERTIFICATE OF SERVICE I hereby certify that a true copy of the foregoing "Plaintiff's Unopposed Motion For An Enlargement Of Time" 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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Case 1:02-cv-00796-FMA

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Filed 04/01/2004

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