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Case 9:08-cv-80380-KAM Document 68 Entered on FLSD Docket 03/18/2009 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80380-MARRA-JOHNSON JANE DOE NO. 4, Plaintiff, V. JEFFREY EPSTEIN, Defendant. I -------------- DEFENDANT EPSTEIN'S MOTION TO EXCEED PAGE LIMITATION IN RESPONSE TO PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND PRODUCTION OF DOCUMENTS, INCLUDING SUPPORTING MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, moves to exceed the page limitation of 20 pages imposed by Loe. Gen. Rule 7.1. C. 2. (S.D. Fla.), in his supporting memorandum of law in response to Plaintiff's Motion to Compel Answers to Interrogatories and Production of Documents, and Incorporated Memorandum of Law In Support, dated March 2, 2009. In support of his motion, Defendant states: 1. This motion is being filed in an abundance of caution. 2. Local Gen. Rule 7.1 C. 2. provides in part that "absent prior permission of the court, no party shall file any legal memorandum exceeding twenty pages in length." Defendant is in the process of preparing his Response and Incorporated Memorandum of Law to Plaintiff's Motion to Compel, dated March 2, 2009, (and due by an extension to March 25, 2009). Although the memorandum of law incorporated into the response Case 9:08-cv-80380-KAM Document 68 Entered on FLSD Docket 03/18/2009 Page 2 of 4 Jane Doe No. 4 v. Epstein Page2 will be less than 20 pages, it is likely that the entire response, including the memorandum, will be in excess of 20 pages. 3. A length exceeding 20 pages is required so that Defendant may fully address the issues raised in Plaintiff's motion to compel which are directed to Defendant's answers to interrogatories and Defendant's response to Plaintiff's production request. Plaintiff served 23 interrogatories and 25 production requests to which Defendant raised individualized constitutional guarantees and additional objections. In order to present Defendant's response in an organized and understandable manner, the 20 page limitation is required to be exceeded. WHEREFORE, Defendant respectfully requests that this Court grant Defendant's motion, and enter an order allowing a response, including memorandum of law, which is in excess of 20 pages. Rule 7.1 Certification the request to exceed 20 pages herein. . ritton, Jr. Attorney for Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of reco/~~}.ltified o~ fol~ Service List in the manner specified by CM/ECF on this 15:Pcfay of y( au • 009: Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Case 9:08-cv-80380-KAM Document 68 Entered on FLSD Docket 03/18/2009 Page 3 of 4 Jane Doe No. 4 v. Epstein Page 3 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ssm@sexabuseattorney.com ahorowitz@sexabuseattorney.com Counsel for Plaintiff Jane Doe #4 Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 jagesg@bellsouth.net Co-Counsel for Defendant Jeffrey Epstein By:___,=------;------- ROBER D. C TTON, JR., ESQ. Florida Bar No. 224162 rcrit@bclclaw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpike@bclclaw.com BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 561/842-2820 Phone 561/515-3148 Fax ( Co-Counsel for Defendant Jeffrey Epstein) Case 9:08-cv-80380-KAM Document 68 Entered on FLSD Docket 03/18/2009 Page 4 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80380-MARRA-JOHNSON JANE DOE NO. 4, Plaintiff, V. JEFFREY EPSTEIN, Defendant. _____________ / ORDER ON DEFENDANT EPSTEIN'S MOTION TO EXCEED PAGE LIMITATION IN RESPONSE TO PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND PRODUCTION OF DOCUMENTS, INCLUDING SUPPORTING MEMORANDUM OF LAW This matter came before the Court on Defendant's, JEFFREY EPSTEIN, Motion to Exceed Page Limitation in Response to Plaintiff's Motion to Compel Answers to Interrogatories and Production of Documents, Including Supporting Memorandum of Law. Having considered Defendant's motion and Plaintiff's counsel being in agreement with the request to exceed page limitaton, it is HEREBY ORDERED and ADJUDGED that: Defendant's motion is GRANTED. Defendant's Response to Plaintiff's Motion to Compel Answers to Interrogatories and Production of Documents, Including Supporting Memorandum of Law may exceed 20 pages. DONE and ORDERED this __ day of _______ , 2009. Kenneth A. Marra United States District Judge Courtesy Copies: Counsel of Record