Free Motion for Extension of Time to Amend - District Court of Federal Claims - federal

Case 1:04-cv-00632-LJB

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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. 04-632C (Judge Bush)

PLAINTIFF'S UNOPPOSED MOTION FOR LEAVE TO FILE AN AMENDED MOTION IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT AND MOTION FOR ENLARGEMENT OF TIME TO FILE ITS AMENDED OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT Plaintiff, Information Systems & Networks Corporation ("plaintiff or ISN"), by its undersigned attorney, moves this Honorable Court for an Order, pursuant to RCFC Rule 6(b), granting ISN a 7 day enlargement of time to July 29, 2005 to file its Amended Opposition to Defendant's Motion for Summary Judgment filed on June 22, 2005. This motion

also seeks leave of the Court to file the Amended Opposition. following: 1. 2. This motion is unopposed. On June 22, 2005, counsel for defendant telephoned In support of this motion, ISN states the

ISN's counsel to indicate that the Plaintiff's Proposed Findings of Uncontroverted Fact, submitted along with Plaintiff's Opposition to Defendant's Motion for Summary Judgment ("Opposition"), filed on June 22, 2005, did not conform to the requirements of RFCF 56. Because ISN's

Opposition refers to Plaintiff's Proposed Findings of

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Unconvtroverted Fact, ISN must now file an amended Opposition to which defendant's counsel consented. 3. On June 22, 2005, ISN's counsel conferred via

telephone and e-mail with defendant's counsel as required by RCFC Rule 6.1. Defendant's counsel indicated that he would

not oppose the motion for an enlargement of time and he further agreed to a 7-day enlargement of time from June 22, 2005, in order to permit ISN to amend its Opposition and submit responses to the uncontroverted along with Plaintiff's uncontroverted facts in conformity with RCFC Rule 56, to June 29, 2005. WHEREFORE, for the reasons stated, ISN respectfully requests that this Court enter an Order granting ISN's Unopposed Motion for Leave to File It's Amended Opposition to Defendant's Motion for Summary Judgment and Motion for Enlargement of Time to File Its Amended Opposition to Defendant's Motion for Summary Judgment and further order that the deadline for filing ISN's Amended Opposition to Defendant's Motion for Summary Judgment be extended to June 29, 2005, 7 days from today. Dated: June 22, 2005 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

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Counsel for Plaintiff

CERTIFICATE OF SERVICE I hereby certify that a true copy of the foregoing Plaintiff's UNOPPOSED MOTION FOR LEAVE TO FILE IT'S AMENDED OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT AND MOTION FOR ENLARGEMENT OF TIME TO FILE ITS AMENDED OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT was filed electronically this 22nd day of June, 2005, and served via email on counsel for defendant by virtue of electronic filing.

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

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