Case 9:10-cv-80309-KAM

Document 7

Entered on FLSD Docket 03/25/2010

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# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

# CASE NO. 10-80309-CIV-Marra/Johnson

JANE DOE No. 103,
 Plaintiff,
 vs.
JEFFERY EPSTEIN,
 Defendant.
/

## DEFENDANT EPSTEIN'S MOTION TO EXCEED PAGE LIMITATION ON MOTION TO DISMISS, & FOR MORE DEFINITE STATEMENT & STRIKE DIRECTED TO PLAINTIFF JANE DOE NO. 103'S COMPLAINT (dated 2/23/20101

Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, moves to exceed the page limitation of20 pages imposed by Loe. Gen. Rule 7.1. C. 2. (S.D. Fla.), in his response to Plaintiff JANE DOE NO. 103 's Complaint, dated February 23, 2010. In support of his motion, Defendant states:

1. 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 to Plaintiffs Complaint, (presently due on March 26, 2010, but Plaintiff has agreed to an extension until April 5, 2010), and the response will exceed the 20 page limitation. It is clear, based on the issues raised in Plaintiffs Complaint that in excess of 20 pages is required to fully and adequately respond to and discuss the issues raised. Defendant anticipates needing to exceed the page limitation for his legal memorandum by 6 to 8 pages.

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2. A length exceeding 20 pages is required so that Defendant may fully address the issues raised in Plaintiffs Complaint which attempts to assert six counts pursuant to I 8 U.S.C. §2255. Under the constitutional guarantees of due process, including a fair and full opportunity to be heard, and in the interests of justice so that the Court may render a fully informed decision on the issue, Defendant is entitled to an order granting his motion to exceed the 20 page limitation in his response.

3. As certified below herein, Plaintiffs counsel agreed to the request to exceed 20 pages.

WHEREFORE, Defendant respectfully requests that this Court grant Defendant's motion, and enter an order allowing a response in excess of 20 pages.

## Local Rule 7.1 Statement

Counsel for the movant conferred with Counsel for the Plaintiff and Counsel for Plaintiff is in agreement with the requested filing in excess of twenty pages in Defendant's response to Plaintiffs Amended Complaint.

Isl  Michael J. Pike
Robert D. Critton, Attorney for
Defendant 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 record identified on the following Service List in the manner specified by CM/ECF on this 23rd day of March, 2010.

| Robert C. Josefsberg, Esq.        | Jack Alan Goldberger, Esq.         |
|-|-|
| Katherine W. Ezell, Esq.          | Atterbury Goldberger & Weiss, P.A. |
| Podhurst Orseck, P.A.             | 250 Australian Avenue South        |
| 25 West Flagler Street, Suite 800 | Suite 1400                         |

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Case 9:10-cv-80309-KAM

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Entered on FLSD Docket 03/25/2010

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Miami, FL 33130
305 358-2800
Fax: 305 358-2382
rjosefsberg@podhurst.com 
kezell@podhurst.com 
Counsel for Plaintiff

West Palm Beach, FL 33401-5012
561-659-8300 
Fax: 561-835-8691
jagesg@bellsouth.net 
Counsel for Defendant Jeffrey Epstein

Respectfully submitted,

By:  Isl  Michael J. Pike
ROBERT D. CRITTON, JR., ESQ.
Florida Bar No. 224162
rcrit@bclclaw.com 
MICHAEL J. PIKE, ESQ.
Florida Bar #617296
mpike@bclclaw.com 
BURMAN, CRITTON, LUTTIER &
COLEMAN 
303 Banyan Blvd., Suite 400
West Palm Beach, FL 33401
561/842-2820 Phone
561/515-3148 Fax
(Counsel for Defendant Jeffrey Epstein)

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documents/doj-5d8cda87204b8788.pdf
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