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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 94-2183-CIV-ATKINS CUBAN AMERICAN BAR ASSOCIATION, INC. ) et. al. ) ) Plaintiff, ) ) vs. ) ) WARREN CHRISTOPHER, et. al. ) ) Defendants, ) ) HAITIAN REFUGEE CENTER, INC., ) et. al. ) Intervenors. ) ________________________________________)
Plaintiffs, HAITIAN REFUGEE CENTER, INC., GARRY JOSEPH, PAULOMIE EDMOND, and PIERRE ONEL ANTOINE, (the Haitian Refugee Plaintiffs); VOIDIEU PIERRE LOUIS, BERGELINE JEAN LOUIS and PADECI JEAN LOUIS (the Minor Plaintiffs); on behalf of themselves and all others similarly situated, by and through their undersigned counsel hereby respectfully request this Honorable Court to grant this motion and grant Intervenor Plaintiffs leave to exceed the page limit set forth in Local Rule for the Southern District of Florida 7.1C(2). The grounds for this motion are as follows:
1. Local Rule 7.1C(2) authorizes this Court to grant leave to file a Memorandum of Law in excess of the 20 page limit set forth in the Rule.
2. Intervenor Plaintiffs have filed a 33 page Memorandum of Law in support of their Motion for Temporary Restraining Order.
3. Although Intervenor Plaintiffs' counsel attempted to streamline the memorandum as such as possible, due to the complexities and the number of issues involved in this case, the Memorandum of Law in Support of the Temporary Restraining Order exceeds the page limit.
4. No party will be prejudiced by a grant of this motion.
WHEREFORE, Intervenor Plaintiffs respectfully requests this Honorable Court to grant its Motion for leave to Exceed Page Limit.
I HEREBY CERTIFY that a true and correct copy of the foregoing was served hand-delivery this 31 day of October, 1994 to: Dexter Lee, Esq., AUSA, Office of the United States Attorney, 99 N.E. 4th Street, Miami, Florida 33132; and Roberto Martines, Esq., Greenberg Traurig, 1221 Brickell Avenue, Miami , Florida 33131
IRA J. KURZBAN, ESQ.