UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA¶
Case No. 0:16-mc-61262-JEM¶
In re: SUBPOENA TO¶
J.¶
Underlying Case:¶
Plaintiff¶
v.¶
GHISLA1NE MAXWELL,¶
Defendant¶
No. 15-cv-07433-RWS (S.D.N.Y)¶
MOTION OF J. TO FILE AN OVER LENGTH REPLY IN SUPPORT OF HIS MOTION TO QUASH SUBPOENA OR, IN THE ALTERNATIVE. FOR A PROTECTIVE ORDER¶
COME NOW J. by and through undersigned counsel, to file this motion for leave to file a reply not to exceed 25 pages in support of his Motion to Quash Subpoena or, in the Alternative, for a Protective Order in this action.¶
As the Court is aware, on June 13, 2016, J. filed a twenty page motion to quash a subpoena that had been served on him by Defendant Maxwell in connection with a complicated case in the Southern District of New York, v. Maxwell, No. 15-cv-07433- RWS (S.D.N.Y.). The motion was supported by seven exhibits. The Court opened the case as a miscellaneous case.¶
On June 30, 2016, Defendant Maxwell filed a sixteen-page response to the Motion to Quash. The response made allegations about whether had engaged in proper filings in other court cases. The response also suggested that, had withheld discovery information that she was required to produce in the Southern District of New York. The response was supported by 18 exhibits, including 5 exhibits that were under seal. The exhibits total approximately 200 pages in length.¶
has now drafted a reply to the response filed by Maxwell. The reply contains nine pages of introductory and factual material and fourteen pages of argument. The fourteen pages of argument are required to fully address the issues raised by Maxwell's response, including discussing recent developments in the underlying case in the Southern District of New York. The subpoena at issue contains multiple sub-pans and a number of complicated issues are presented by the requests it contains.¶
Opposing counsel have been contacted for a position on the motion. Plaintiff will supplement this motion once such position has been obtained.¶
DATED: July 7, 2016¶
Respectfully Submitted,¶
/s/ Jack Scarola¶
Jack Scarola¶
Florida Bar No.: 169440¶
Attorney E-Mail(s): jsx@searcylaw.com and mep@searcylaw.com¶
Primary E-Mail: _scarolateam@searcylaw.com¶
Searcy Denney Scarola Barnhart & Shipley, P.A.¶
2139 Palm Beach Lakes Boulevard¶
West Palm Beach, Florida 33409¶
Phone: (561) 686-6300¶
Fax: (561) 383-9451¶
Attorney Jrb non- tarty respondent¶
J.¶
CERTIFICATE OF SERVICE¶
I certify that on July 7, 2016, I electrically served the foregoing pleading via the Court's CM/ECF filing system on:¶
Laura A. Menninger Jeffrey S. Haddon, and P.C. 150 East 101 Avenue Denver, CO 80203 Phone: (303) 831-7364 Fax: (303) 832-2628 Imenninger@hmflaw.com¶
Attorneys for Ghislaine Maxwell¶