State Of New York et al v. Mnuchin et al

Filing 40

JOINT LETTER MOTION for Leave to File Excess Pages addressed to Judge J. Paul Oetken from Rebecca S. Tinio dated October 30, 2018. Document filed by David J Kautter, Steven T. Mnuchin, United States Department of Treasury, United States Internal Revenue Service.(Tinio, Rebecca)

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U.S. Department of Justice [Type text] United States Attorney Southern District of New York 86 Chambers Street New York, New York 10007 October 30, 2018 BY ECF The Honorable J. Paul Oetken United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 Re: State of New York, et al. v. Mnuchin et al., No. 18 Civ. 6427 (JPO) Dear Judge Oetken: This Office represents Treasury Secretary Steven Mnuchin, in his official capacity; the U.S. Department of the Treasury; Commissioner of Internal Revenue Charles P. Rettig, in his official capacity; the Internal Revenue Service; and the United States of America (together, the “Government”), the defendants in the above-referenced action. We write respectfully on behalf of all parties in this case to request an enlargement of the Court’s normal page limitations with respect to the Government’s upcoming motion responding to the Complaint, the States’ anticipated cross-motion, and the parties’ respective oppositions and replies. See Dkt. No. 38 (describing the parties’ anticipated briefing). The parties have conferred and respectfully request that they be permitted to file 60 pages total per side. The Government anticipates that its opening brief will be approximately 35 pages, with the balance of the pages to be used in its reply and opposition. The States anticipate that their opposition and cross-motion will be 40 pages, and that their reply will be 20 pages. We thank the Court for its consideration of this request. Respectfully, GEOFFREY S. BERMAN United States Attorney By: __s/Rebecca S. Tinio____________ JEAN-DAVID BARNEA REBECCA S. TINIO Assistant United States Attorneys Tel. (212) 637-2679/2774 Fax (212) 637-2686 Cc: All counsel of record (by ECF)

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