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

Case 1:04-cv-00748-EJD

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Filed 08/26/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS INFORMATION SYSTEMS & NETWORKS CORPORATION, ) ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES OF AMERICA, ) ) Defendant. )

No. 04-748C (Judge Damich)

PLAINTIFF'S CONSENT MOTION FOR ENLARGEMENT OF TIME TO FILE ITS OPPOSITION TO DEFENDANT'S MOTION TO DISMISS Plaintiff, Information Systems & Networks Corporation ("plaintiff or ISN"), by its undersigned attorneys, moves this Honorable Court for an extension of the filing date for Plaintiff's Opposition to Defendant's Motion to Dismiss. ISN requests an enlargement of time of 45 days, from August 30 to October 14, 2004. requested enlargement. The enlargement is necessary for three reasons: 1. The principals of ISN, including its president and The defendant consents to the

CEO, have been unavailable for a significant portion of July and August due to vacation and business travel. Their input

and availability is necessary in preparing the opposition. 2. ISN's counsel is engaged in other matters

requiring extensive time, including briefs regarding dispositive motions in three different matters in this Court; six previously-scheduled depositions in the month of September; and participation in a week-long trial in the

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United States District Court for the District of Maryland beginning October 4, 2004. 3. ISN's counsel was on vacation for two weeks during

the month of August. WHEREFORE, for the reasons stated, Information Systems & Networks Corporation requests an enlargement of the time for it to file its Opposition to Defendant's Motion to Dismiss up to and including October 14, 2004. Dated: August 26, 2004 Respectfully submitted, SINGER & ASSOCIATES, PC

By:

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

CERTIFICATE OF SERVICE I hereby certify that a true copy of the foregoing "PLAINTIFF'S CONSENT MOTION FOR ENLARGEMENT OF TIME TO FILE ITS OPPOSITION TO DEFENDANT'S MOTION TO DISMISS" was filed electronically this 26th day of August, 2004, and served via email on counsel for defendant by virtue of electronic filing.

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

Case 1:04-cv-00748-EJD

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