EFTA00602257.pdf

Case 9:08-cv-80736-KAM Document 301 Entered on FLSD Docket 01/29/2015 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Plaintiffs, vs. UNITED STATES OF AMERICA, Defendant. NON PARTY ALAN M. DERSHOWITZ'S UNOPPOSED MOTION FOR LEAVE TO FILE HIS REPLY IN SUPPORT OF HIS MOTION FOR LIMITED INTERVENTION NOT TO EXCEED EIGHTEEN (18) PAGES Alan M. Dershowitz, through undersigned counsel, hereby files this Unopposed Motion for Leave to File a Reply in Support of his Motion for Limited Intervention not to Exceed Eighteen (18) Pages, and in support thereof states as follows: I. On December 30, 2014 Jane Does 3 and 4 filed a Motion for Joinder in this action (DE 279), which included slanderous allegations against Alan M. Dershowitz (herein "Prof. Dershowitz.") 2. Prof. Dershowitz filed a motion for limited intervention for the limited purposes of moving to strike the outrageous and impertinent allegations made against him and requesting a show cause order to the attorneys that have made them, as well as a short supplement to that motion. (DE 282 and 285.) 3. Jane Does 1 - 4 filed a motion for leave to file a consolidated response to Prof. Dershowitz' s motion and for leave to file a 38 page response. (DE 288.) The undersigned agreed not to oppose the motion. At that time counsel for Jane Does 1 - 4 agreed that they EFTA00602257 Case 9:08-cv-80736-KAM Document 301 Entered on FLSD Docket 01/29/2015 Page 2 of 3 would not oppose Prof. Dershowitz's request to file a 19 page reply. The Court granted Jane Does I - 4's unopposed motion. (DE 289.) 4. As expected, Jane Does 1 - 4 filed a thirty-eight (38) page response on January 21, 2015. (DE 291) (herein "Response.") Additionally, thirty (30) exhibits including correspondence, pleadings, deposition transcripts, and more, were attached to the Response as well. 5. Given the length of Plaintiffs' Response and the amount of material attached thereto, Prof. Dershowitz will need the agreed upon extra eight (8) pages to adequately reply to the Response. Prof. Dershowitz's Reply is due to be filed this Monday, February 2, 2015. 6. Counsel for Jane Does 1 - 4 have agreed that they do not oppose the relief sought herein. WHEREFORE, non-party Alan M. Dershowitz respectfully requests leave to file a Reply in Support of his Motion for Limited Intervention not to exceed eighteen (18) pages. Dated: January 29, 2015 Respectfully submitted, /s/ Gabriel Groisman Kendall Coffey, Fla. Bar No. 259681 Gabriel Groisman, Fla. Bar No. 25644 Benjamin H. Brodsk Fla. Bar No. 73748 COFFEY BURLINGTON, 2601 South Bayshore Drive, PH 1 Miami, Florida 33133 Telephon Facsimile Counselfor Prof. Alan M. Dershowitz 2 EFTA00602258 Case 9:08-cv-80736-KAM Document 301 Entered on FLSD Docket 01/29/2015 Page 3 of 3 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served by Notice of Electronic Filing generated by CM/ECF, on this 29th day of January, 2015, on all counsel or parties of record on the Service List below. Is/ Gabriel Groisman SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, ■. UNITED STATES ATTORNEY'S OFFICE 425 North Andrews Avenue, Suite 2 500 S. Australian Ave., Suite 400 Fort Lauderdale, Florida 33301 11.1.11 West Palm Beach, FL 33401 Telephon Facsimile E-mail: 4CP and Attorneys for the Government Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Attorneys for Jane Doe #1, Z 3, and 4 3 EFTA00602259