EFTA00178969¶
8/17/2007 3:27 PM FROM: William L. Richey, P William L. Richey, P.A. TO:¶
PAGE: 002 OF 005¶
UNITED STATES DISTRICT COURT¶
SOUTHERN DISTRICT OF FLORIDA FGJ 07-103 (WPB)¶
IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-63 & OLY-64¶
MOTION OF AND FOR AN EXTENSION OF TIME NUNC PRO TUNC TO FILE THEIR REPLY¶
and (““). by and through undersigned counsel, respectfully request for an enlargement of time. nunc pro tunc, to file their Reply to the Government’s Response to the Motion to Intervene and to Quash Grand Jury Subpoenas and Cross Motion to Compel. In support thereof. states as follows:¶
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Undersigned counsel has been out of the country recently, only returning on August 11, 2007. By that time, the time to reply to the Government’s Response to the Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross Motion to Compel had already expired.
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Undersigned counsel received a copy of the Reply filed by Jeffrey Epstein yesterday, August 16, 2007. Counsel has now reviewed that filing, along with the Government’s response.
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reply is being filed concurrently with this request for an extension of time.
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Counsel attempted to contact the AUSA in this case to determine whether she would consent to the relief requested herein, however, she is unavailable until next Thursday. August 23, 2007. Accordingly, to prevent further delay, this request is being filed at this time.
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This request is not made for the purpose of delay.
EFTA00178970¶
8/17/2007 3:27 PM FROM: William L. Richey, P William L. Richey, P.A. TO: 1-561-802-1787 PAGE: 003 OF 005¶
FGJ 07-103 (WPB)¶
WHEREFORE and respectfully request that the Court enter an order granting them an extension of time nunc pro tunc to file their Reply to the Government’s Response to the Motion to Intervene and to Quash Grand Jury Subpoenas and Cross Motion to Compel.¶
Respectfully submitted.¶
WILLIAM L. RICHEY, P.A.¶
201 South Biscayne Boulevard¶
34th Floor. Miami Center¶
Miami, Florida 33131¶
CERTIFICATE OF SERVICE¶
I hereby certify that on August 17, 2007, the foregoing document will be served via facsimile and U.S. Mail on counsel, as listed on the attached service list. This document was not filed using CM/ECF because it is being filed under seal.¶
-2.¶
William L. Richey, P.A. mer, Miami, Florida 33131-4325¶
201 South Biscayne Boulevard, 34th Floor, Miami Center, Miami, Florida 33131-4325¶
EFTA00178971¶
8/10/2007 3:27 PM FROM: William L. Richey, P William L. Richey, P.A. TO: 1-561-802-1787 PAGE: 004 OF 005¶
FGJ 07-103 (WPB)¶
Service List¶
In re: Grand Jury Subpoenas¶
FGJ 07-103 (WPB)¶
United States District Court, Southern District of Florida¶
Assistant US Attorney¶
500 South Australian Avenue. Suite 400¶
West Palm Beach, Florida 33401¶
Roy Black, Esquire¶
Black Srebnick Kornspan & Stumpf¶
201 South Biscayne Boulevard, Suite 1300¶
Miami, Florida 33131¶
Fax:¶
-3.¶
201 South Biscayne Boulevard, 34th Floor, Miami Center, Miami, Florida 33131-4325¶