Free Disclosure Statement - Rule 7.1 - District Court of Federal Claims - federal

Case 1:06-cv-00099-LB

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Filed 11/03/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) INFORMATION SYSTEMS & ) NETWORKS CORPORATION, ) ) Plaintiff, ) ) Case No. 1:06-cv-99 v. ) Judge Block ) THE UNITED STATES, ) ) Defendant, ) ____________________________________) PLAINTIFF'S INITIAL RULE 26 DISCLOSURES Pursuant to the Rule 26(a) of the Rules of the United States Court of Federal Claims ("RCFC"), plaintiff, Information Systems & Networks Corporation ("plaintiff" or "ISN"), by its undersigned attorneys, hereby discloses the following information as required by RCFC 26(a): RESERVATION OF RIGHTS 1. To the extent that general discovery provides additional information, which requires a supplementation of these Initial Disclosures, plaintiff submits these Initial Disclosures under condition that they may be amended based upon such newly discovered information. 2. Plaintiff reserves the right to amend, supplement or withdraw these Initial Disclosures, including the addition of additional expert witnesses, if in general discovery including document production, such additional designations are required. In responding to these Initial Disclosures, plaintiff has conducted a reasonable inquiry with respect to expert testimony; have consulted documents in its possession and its knowledge of pertinent events.

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Case 1:06-cv-00099-LB

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DISCLOSURES 1. Persons Likely to Have Discoverable Information: Roma Malkani, ISN, 10411 Motor City Drive, Bethesda, MD 20817. Sonya Lyles, ISN, 10411 Motor City Drive, Bethesda, MD 20817. Charles Bonuccelli, 8450 Greensboro Drive, McLean, VA 22102. John Svensson, DCMA, 217 East Redwood Street, Baltimore, MD 21202. Ellen Erdelsky, DCAA, Germantown, MD. Mark Moser, DCAA, Germantown, MD. 2. Description by category and location of all documents in the possession of ISN: Documents pertinent to the indirect rate issues as alleged in the Complaint are located at the offices of ISN, 10411 Motor City Drive, Bethesda, MD. 3. Computation of any category of damages claimed by ISN: ISN claims that the disputed items of cost as alleged in the Complaint be deemed allowable and be included in ISN's indirect cost rates for FY 1987-1995. ISN has not calculated to date the monetary differences this inclusion will create from the indirect rates that have been deemed allowable once these calculations are completed, ISN intends on amending its Complaint to seek a monetary judgment for the total increased amount caused by the allowability. 4. Disclosure of expert testimony. Plaintiff can identify the following persons who may be used at trial to present evidence under RCFC 702, 703, or 705: (a) Charles Bonuccelli (address previously provided). Mr. Bonuccelli has not prepared a report to date.

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Case 1:06-cv-00099-LB

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(b) Michael A. Smigocki, 15850 Crabbs Branch Way, Rockville, MD 20855. Mr. Smigocki has not prepared a report to date. (c) Plaintiff intends for either or both Mr. Bonuccelli and/or Mr. Smigocki to provide a written report which shall contain a complete statement of all opinions to be expressed and the basis and reasons therefore; the data or other information considered in forming the opinions; any exhibits to be used as a summary of or support for the opinions. The report(s) shall be submitted either on a date agreed upon between the parties but at least 70 days before scheduled close of discovery. (d) It is the intention of the plaintiff to submit the expert reports in such an agreed upon time sequence that the respective experts will have the ability to utilize general discovery in the preparation of their expert reports.

/s/ NORMAN H. SINGER, ESQ. Singer & Associates, PC 10411 Motor City Drive Suite 725 Bethesda, MD 20817 (P) 301-469-0400 (F) 301-469-0403

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Case 1:06-cv-00099-LB

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Filed 11/03/2006

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CERTIFICATE OF FILING I hereby certify that on November 3, 2006, a copy of the foregoing Initial Disclosures was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. /s/ NORMAN H. SINGER, ESQ.

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