Case 9:08-cv-80119-KAM Document 62 Entered on FLSD Docket 03/18/2009

Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, 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 Plaintiffs 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-80119-KAM Document 62 Entered on FLSD Docket 03/18/2009

Page 2 of 4 Doe 2 v. Epstein Page 2 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 Pursuant to communication by telephone, Plaintiff's counsel has no objection to the request to exceed 20 pages herein. Robert D. Critton, 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 recqr-J:},Jdentified on the following Service List in the manner specified by CM/ECF on thisL<Gtfay of March, 2009: Adam D. Horowitz, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Case 9:08-cv-80119-KAM Document 62 Entered on FLSD Docket 03/18/2009

Page 3 of 4 Doe 2 v. Epstein Page 3 305-931-2200 Fax: 305-931-0877 [email protected] [email protected] [email protected] Counsel for Plaintiff Jane Doe #2 561-659-8300 Fax: 561-835-8691 [email protected] Co-Counsel for Defendant Jeffrey Epstein By: -----.f--+>=,...._ ___ _ ROBER C ITTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 561-842-2820 Fax: 561-515-3148 (Co-counsel for Defendant Jeffrey Epstein) Case 9:08-cv-80119-KAM Document 62 Entered on FLSD Docket 03/18/2009