EFTA00184011 IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA, FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, CASE NO. 4D09-2554 PALM BEACH COUNTY L.T. CASE NO. 2008 CF 009381A STATE OF FLORIDA, Respondent. ##
AGREED MOTION TO FILE ONE REPLY SUPPORTING PETITION FOR WRIT OF CERTIORARI AND FOR THE TIME TO RUN FROM SERVICE OF THE LAST-FILED RESPONSE
Petitioner, JEFFREY EPSTEIN, requests this Court’s permission to file one reply supporting his petition for certiorari to the three separate responses filed by respondents and for the time to run from service of the last-filed response, for the following reasons: 1. Mr. Epstein filed an Emergency Petition for Certiorari to review an order compelling disclosure of a confidential federal non-prosecution agreement and addendum. 1 EFTA00184012 2. On July 1, 2009, this Court ordered respondent to show cause within 10 days why the petition should not be granted. This Court allowed Mr. Epstein 10 days to reply. 3. Three groups of respondents filed responses: (1) .; (2) .; and (3) Palm Beach Newspapers, Inc. d/b/a Palm Beach Post (“the Post”). Each respondent is represented by different counsel. The responses were served by mail and on different days. 4. Due to the overlap of arguments in the three responses, it would benefit the parties and this Court if Mr. Epstein filed one reply to the three responses. Accordingly, Mr. Epstein requests permission to file one reply to the three responses. Mr. Epstein requests this Court to order that the reply is due 10 days from service of the last-filed response. Opposing counsel has contacted counsel for respondents (William J. Berger for ; Diana L. Martin for ; and Deanna K. Shullman for the Post), who have all advised they have no objection to this motion. 2 EFTA00184013 email and I HEREBY CERTIFY that a copy of the foregoing has been sent by mail this 14th day of July, 2009, to: U. S. Attorney’s Office-Southern District 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 WILLIAM J. BERGER ROTHSTEIN ROSENFELDT ADLER 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 Counsel for State Attorney’s Office-West Palm Beach 401 North Dixie Highway West Palm Beach, FL 33401 DEANNA K. SHULLMAN 400 North Drive, Suite 1100 P. O. Box 2602 (33601) Tampa, FL 33602 Counsel for The Palm Beach Post SPENCER T. KUVIN DIANA L. MARTIN LEOPOLD-KUVIN, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Counsel for HONORABLE JEFFREY COLBATH 15th Judicial Circuit Palm Beach County Courthouse 205 North Dixie Highway Room 11F West Palm Beach, FL 33401 ROBERT D. CRITTON of BURMAN, CRITTON, LUTTIER & COLEMAN 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401 and JACK A. GOLDBERGER of ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 and 3 EFTA00184014 BARBARA J. COMPIANI of KREUSLER-WALSH, COMPIANI & VARGAS, P.A. 501 South Flagler Drive, Suite 503 West Palm Beach, FL 33401-5913 Counsel for Petitioner By: JANE KREUSLER-WALSH Florida Bar No. 4