Free Motion for Extension of Time to File Response/Reply - 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,)

) ) No. 1:02-CV-796 (Judge Allegra)

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

PLAINTIFF'S CONSENT MOTION FOR EXTENSION OF TIME TO FILE REPLY TO DEFENDANT'S OPPOSITION TO PLAINTIFF'S MOTION FOR PARTIAL 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 its Reply To Defendant's Opposition To Plaintiff's Motion For Partial Summary Judgment -- currently due December 22, 2003. Plaintiff

requests an extension up to and including January 9, 2004, and as grounds therefor states as follows: 1. Pursuant to the Order of this Court entered on November 19, 2003, defendant will be filing its Opposition To Plaintiff's Motion for Partial Summary Judgment on December 15, 2003. Pursuant to the RCFC, Plaintiff's

Reply would be due within seven days, or by December 22, 2003. 2. Plaintiff begins an arbitration on December 15 which will take two days. In addition, plaintiff's counsel

will be absent from his office on Friday, December 19 because of Hanukkah and the following week is Christmas

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and then New Years.

As a result of the Holiday Season,

counsel's office is scheduled to be closed. Accordingly, plaintiff requests the extension to January 9, 2004. 3. The defendant has consented to the extension to January 9, 2004. WHEREFORE, the plaintiff, Information Systems & Networks Corporation, requests that the date for its Reply to Defendant's Opposition to Plaintiff's Motion For Partial Summary Judgment be due January 9, 2004. Dated: November 20, 2003 Respectfully submitted, SINGER & ASSOCIATES, PC

By:

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

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CERTIFICATE OF SERVICE I hereby certify that a true copy of the foregoing "CONSENT MOTION TO EXTEND DUE DATE FOR REPLY" was emailed this 20TH day of November, 2003.

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

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