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)

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
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All counsel of record (by ECF)