Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page The issues being addressed pertain to the interpretation and application of U.S.C Some of these issues include but are not limited to constitutional law issues and what version of U.S.C.A applies to this action and the meaning of with respect to the cause of action created and the presumptive minimum damages amount imposed It is Defendants position that the amended version does NOT apply to this action rather it is the statute in effect during the time of the alleged conduct that apply A length exceeding pages is required so that Defendant may fully address the issues raised in Plaintiffs First Amended Complaint and in seeking dismissal thereof 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 issues Defendant is entitled to an order granting his motion to exceed the page limitation Defendant anticipates that the legal memorandum will be approximately pages in length As certified below Plaintiffs counsel agreed to the request to exceed pages WHEREFORE Defendant respectfully requests that this Court grant Defendants motion and enter an order allowing Defendants legal memorandum in support of dismissal of Plaintiffs action to be in excess of pages Rule Certification Pursuant to communication by telephone Plain ffs counsel has no objection to the request to exceed pages herein Counsel fo Case Document Entered on FLSD Docket Page of Jane Doe II Epstein et al Page 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 recqi:siJP.entifi owing Service List in the manner specified by CM/ECF on this of Robert Josefsberg Esq Katherine Ezell Esq Podhurst Orseck P.A West Flagler Street Suite Miami FL Fax rjosefsberg podhurst.com kezell podhurst.com Counsel for Plaintiff Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Fax jagesq bellsouth.net Counsel for Defendant Jeffrey Epstein Respec ully By t--ll ROB ON JR ESQ Flor rcrit clclaw.com MICHAEL PIKE ESQ Florida Bar mpike bclclaw.com BURMAN CRITTON LUTTIER COLEMAN Flagler Drive Suite West Palm Beach FL Phone Fax Counsel for Defendant Jeffrey Epstein
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