EFTA01098058.pdf

Case 9:08-cv-80736-KAM Document 109 Entered on FLSD Docket 10/14/2011 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. JEFFREY EPSTEIN'S MOTION FOR LEAVE To FILE OVERLONG PLEADING Jeffrey Epstein seeks leave to file his Omnibus Reply in Support of His Motion For Limited Intervention, which is 20 pages. Undersigned counsel communicated with Paul Cassell, counsel for the plaintiffs, who indicated that he did not object to a 15-page reply, but objects to the additional five pages. We are awaiting response from the government on its position on this motion. Mr. Epstein has filed one pleading, replying to all the arguments made by both the plaintiffs and the government concerning Mr. Epstein's motion for limited intervention. Even though Mr. Epstein could have filed two separate replies, each consisting of the 10 pages provided by the Rules, we believe that addressing all of the issues in one document rather than piecemeal by breaking them up into two pleadings is more efficient for all involved, including the Court. We communicated with plaintiffs' counsel some weeks ago and advised them of our intention to file one omnibus reply rather than break up the replies into two pleadings. Plaintiffs' counsel responded in writing that they did not have a problem with that. The issues raised in these and related papers are significant, numerous, and at times complicated. Indeed, the plaintiffs themselves have had to exceed the page limits provided by the EFTA01098058 Case 9:08-cv-80736-KAM Document 109 Entered on FLSD Docket 10/14/2011 Page 2 of 2 Rules in filing their response to the lawyers' supplemental briefing, and they had the benefit and courtesy of being able to file an unopposed motion to exceed the page limit. [DE 105]. We have made every effort to address each issue in an efficient manner, and believe the 20- page omnibus reply is necessary to fully address all the arguments raised by the parties, and in particular the claims made by the plaintiffs that the law does not support the relief requested by Mr. Epstein. A significant portion of the pleading is devoted to citing all the cases that unequivocally rebut the plaintiffs' claims. Accordingly, we respectfully request that the Court grant Mr. Epstein leave to file his overlong omnibus reply in support of his motion for limited intervention. We certify that on October 14, 2011, the foregoing document was filed electronically with the Clerk of the Court using the CM/ECF system. Respectfully submitted, BLACK, SREBNICK, KORNSPAN & STUMPF, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131 Offi Fax: By /S/ ROY BLACK, ESQ. Florida Bar No. 126088 JACKIE PERCZEK, ESQ. Florida Bar No. 0042201 On Behalf opetey Epstein 2 EFTA01098059