Free Motion for Extension of Time to Complete Discovery - 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. UNITED STATES OF AMERICA Defendant : : : : : : Case No. 02-796C : (Judge Allegra) : : :

UNOPPOSED MOTION TO EXTEND EXPERT REPORT FILING DATE AND COMPLETION OF DISCOVERY Plaintiff, Information Systems & Networks Corporation ("Plaintiff" or "ISN"), by its undersigned attorneys, moves this Honorable Court for an extension of the November 21, 2003 filing date for expert reports to February 20, 2004, and an extension of the date for completion of discovery from January 30, 2004 to April 30, 2004. As grounds for this Motion, ISN states as follows: 1. 2. This is the first request for extension of time for discovery in this matter. Pursuant to the Order of this Court filed on January 16, 2003, the parties

were required to exchange expert reports on November 21, 2003, and to complete all discovery by January 30, 2004. The parties request an extension of sixty (60) business days to February 20, 2004 for filing expert reports, and one hundred ten (110) business days to April 30, 2004 for the completion of all discovery. 3. On October 23, 2003, ISN filed a Motion for Partial Summary Judgment as

to the breach of contract count of the Complaint. Defendant's Opposition is due November 24, 2003, and ISN's Reply is due by December 8, 2003. If the Motion for Partial Summary Judgment is denied by the Court, then the parties will need to complete

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discovery on the issue of liability for the breach of contract claim. If the Motion is granted, then no further discovery will be required except for that related to the issue of damages. In addition, the resolution of the Motion will dictate the selection of experts and the nature of their opinions. The proposed extended dates take into account these contingencies. 4. Defendant does not oppose this motion or the revised discovery schedule

set forth herein. WHEREFORE, the plaintiff, Information Systems & Networks Corporation, requests that the filing date for expert reports be extended to February 20, 2004, and the date for completion of all discovery be extended to April 30, 2004. Dated: November 12, 2003 Respectfully submitted, SINGER & ASSOCIATES, P.C.

By:

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

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CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Unopposed Motion to Extend Expert Report Filing Date and Completion of Discovery was sent via electronic filing this 12th day of November, 2003, with a hard copy sent facsimile on November 10, 2003, to:

Brent M. McBurney, Esq. Commercial Litigation Branch Civil Division United States Department of Justice Attn: Classification Unit 8th Floor, 1100 L Street, N.W. Washington, D.C. 20530

___s/ Norman H. Singer_____________ Norman H. Singer, Esq.

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