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Case 9:08-cv-80736-KAM Document 301 Entered on FLSD Docket 01/29/2015 Page 1 of 3

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Case 9:08-cv-80736-KAM Document 301 Entered on FLSD Docket 01/29/2015 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Plaintiffs, vs. UNITED STATES OF AMERICA, Defendant. NON PARTY ALAN M. DERSHOWITZ'S UNOPPOSED MOTION FOR LEAVE TO FILE HIS REPLY IN SUPPORT OF HIS MOTION FOR LIMITED INTERVENTION NOT TO EXCEED EIGHTEEN (18) PAGES Alan M. Dershowitz, through undersigned counsel, hereby files this Unopposed Motion for Leave to File a Reply in Support of his Motion for Limited Intervention not to Exceed Eighteen (18) Pages, and in support thereof states as follows: I. On December 30, 2014 Jane Does 3 and 4 filed a Motion for Joinder in this action (DE 279), which included slanderous allegations against Alan M. Dershowitz (herein "Prof. Dershowitz.") 2. Prof. Dershowitz filed a motion for limited intervention for the limited purposes of moving to strike the outrageous and impertinent allegations made against him and requesting a show cause order to the attorneys that have made them, as well as a short supplement to that motion. (DE 282 and 285.) 3. Jane Does 1 - 4 filed a motion for leave to file a consolidated response to Prof. Dershowitz' s motion and for leave to file a 38 page response. (DE 288.) The undersigned agreed not to oppose the motion. At that time counsel for Jane Does 1 - 4 agreed that they EFTA00602257 Case 9:08-cv-80736-KAM Document 301 Entered on FLSD Docket 01/29/2015 Page 2 of 3 would not oppose Prof. Dershowitz's request to file a 19 page reply. The Court granted Jane Does I - 4's unopposed motion. (DE 289.) 4. As expected, Jane Does 1 - 4 filed a thirty-eight (38) page response on January 21, 2015. (DE 291) (herein "Response.") Additionally, thirty (30) exhibits including correspondence, pleadings, deposition transcripts, and more, were attached to the Response as well. 5. Given the length of Plaintiffs' Response and the amount of material attached thereto, Prof. Dershowitz will need the agreed upon extra eight (8) pages to adequately reply to the Response. Prof. Dershowitz's Reply is due to be filed this Monday, February 2, 2015. 6. Counsel for Jane Does 1 - 4 have agreed that they do not oppose the relief sought herein. WHEREFORE, non-party Alan M. Dershowitz respectfully requests leave to file a Reply in Support of his Motion for Limited Intervention not to exceed eighteen (18) pages. Dated: January 29, 2015 Respectfully submitted, /s/ Gabriel Groisman Kendall Coffey, Fla. Bar No. 259681 Gabriel Groisman, Fla. Bar No. 25644 Benjamin H. Brodsk Fla. Bar No. 73748 COFFEY BURLINGTON, 2601 South Bayshore Drive, PH 1 Miami, Florida 33133 Telephon Facsimile Counsel for Prof. Alan M. Dershowitz 2 EFTA00602258 Case 9:08-cv-80736-KAM Document 301 Entered on FLSD Docket 01/29/2015 Page 3 of 3 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served by Notice of Electronic Filing generated by CM/ECF, on this 29th day of January, 2015, on all counsel or parties of record on the Service List below. Is/ Gabriel Groisman SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, ■. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephon Facsimile E-mail: and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Attorneys for Jane Doe #1, Z 3, and 4 UNITED STATES ATTORNEY'S OFFICE 500 S. Australian Ave., Suite 400 11.1.11 West Palm Beach, FL 33401 4CP 3 Attorneys for the Government EFTA00602259

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Case #9:08-CV-80736-KAM

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Fr • < > Subjec :Deliberative t Process ec aratton rom am Justice - equest or wo ee xtension Date: Fri, 20 Sep 2013 17:59:47 +0000 Importance: Normal We have no objection, provided we get the following accommodation, which you already anticipated. We would request that your motion for extension of time give us an extension on our reply document, such that our reply would be due 10 days after the main Justice Department declaration that will be coming in two weeks. If you would include such language as well in any proposed order, saving us (and the court) drafting time, that would be very much appreciated. Paul Cassell and Brad Edwards for Jane Doe #1 and Jane Doe #2 Paul G Cassell CONFIDENTIAL: This electronic message along with any/all attachments is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 013-80736-Civ-Marra/Nlatthewman JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES, Respondent. DECLARATION OF IN SUPPORT OF GOVERNMENT'S RESPONSE AND OPPOSITION TO PETITIONERS' MOTION FOR PARTIAL SUMMARY JUDGMENT AND CROSS-MOTION FOR SUMMARY JUDGMENT do hereby declare that I am a member in good standing of the Bar of the State of Florida. I also am admitted to practice in all courts of the states of Minnesota and Florida, the Eighth, Eleventh, and Federal Circuit Courts of Appeals, and the U.S. District Courts for the Southern District of Florida, the District of Minnesota, and the Northern District of California. My bar admission status in California and Minnesota is currently inactive. I am currently employed as an Assistant United States Attorney in the Southern District of Florida and was so employed during all of the events described herein. 2. I am the Assistant United States Attorne

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STATEMENT BY ALAN DERSHOWITZ

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