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.
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| 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.
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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.
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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
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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.
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