Montgomery v. Risen et al

RESPONSE in Opposition re MOTION for Leave to File Excess Pages for Motion for Summary Judgment and Statement of Material Facts

S.D. Fla.December 9, 2015

1 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA DENNIS L. MONTGOMERY Plaintiff, v. JAMES RISEN, ET AL., Defendants. Civil Action No. 1:15-cv-20782-JEM PLAINTIFF’S OPPOSITION TO MOTION TO EXCEED PAGE LIMITATIONS FOR SUMMARY JUDGMENT AND STATEMENT OF FACTS Plaintiff opposed the request to exceed the page limit because the amount of extra pages proposed was "excessive." Plaintiff's counsel asked that his full position be included in any motion, but Defendants counsel intentionally left this out. Plaintiff and his counsel have reason to believe that the requested excess pages will be primarily used to wage ad hominem personal attacks, belittling Plaintiff's state of deteriorating health (as they attempted before Judge Martinez during the first status conference and in subsequent proceedings, such as at Plaintiff's deposition), and disparaging and degrading Plaintiff's counsel, as they have done in the past. All of this is purely for strategic reasons and has no relevance. Accordingly, Plaintiff and his counsel do not see the need to exceed the standard page limit as set forth in this Court's local rules so the space can be used for these personal and unnecessary ad hominem attacks. Dated: December 9, 2015 Case 1:15-cv-20782-JEM Document 192 Entered on FLSD Docket 12/09/2015 Page 1 of 3 2 Respectfully submitted, /s/ Larry Klayman Klayman Law Firm FL Bar No. 246220 7050 W Palmetto Park Rd. Suite 15-287 Boca Raton, FL 33433 (310) 595-0800 leklayman@gmail.com Attorney for Plaintiff Case 1:15-cv-20782-JEM Document 192 Entered on FLSD Docket 12/09/2015 Page 2 of 3 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 9th day of December, 2015, a true and correct copy of the foregoing was filed and served via CM/ECF upon the following: Sanford Lewis Bohrer Brian Toth Holland & Knight, LLP Suite 3000 701 Brickell Ave Miami, FL 33131 Email: sbohrer@hklaw.com Email: brian.toth@hklaw.com Laura R. Handman Micah Ratner Davis Wright Tremaine LLP 1919 Pennsylvania Ave., N.W., Suite 800 Washington D.C. 20006-3401 Email: laurahandman@dwt.com Email: MicahRatner@dwt.com Attorneys for Defendants /s/ Larry Klayman Larry Klayman, Esq. Case 1:15-cv-20782-JEM Document 192 Entered on FLSD Docket 12/09/2015 Page 3 of 3