IN THE DISTRICT COURT OF APPEAL FOR THE FIRST DISTRICT, STATE OF FLORIDA

Transcription

1 JOANNE MCCALL, et al., IN THE DISTRICT COURT OF APPEAL FOR THE FIRST DISTRICT, STATE OF FLORIDA RECEIVED, 9/8/2015 1:13 PM, Jon S. Wheeler, First District Court of Appeal v. Appellants, RICK SCOTT, GOVERNOR OF FLORIDA, et al., Appellees. Case No. 1D L.T. Case No: 2014-CA-2282 STATE APPELLEES UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO SERVE ANSWER BRIEF Pursuant to Rule 9.300, the State Appellees, Rick Scott, Governor of Florida, Pam Bondi, Attorney General of Florida, Jeff Atwater, Chief Financial Officer, Adam Putnam, Commissioner of Agriculture, Pam Stewart, Commissioner of Education, the Florida Department of Revenue, and the Florida Department of Education, move for a 60-day extension of time in which to serve their Answer Brief. 1. Appellants served their Initial Brief on August 21, Under Florida Rule of Appellate Procedure 9.210(f) and Florida Rule of Judicial Administration 2.514(b), the State Appellees Answer Brief is currently due to be served September 15, The State Appellees seek a 60-day extension of time in which to serve their Answer Brief, up to and including November 16,

2 2. The Florida Solicitor General s Office, which is handling this appeal for State Appellees, has numerous case assignments with pressing deadlines. Specifically, the attorneys involved in this case are also involved in matters with the following deadlines: a) September 8, 2015 Answer Brief in Miles v. City of Edgewater Police Department (First District Court of Appeal, No. 1D ) b) September 25, 2015 Initial Brief in Department of Revenue v. DirecTV (Florida Supreme Court, No. SC ) c) September 25, 2015 Initial Brief in K.G. v. Dudek (Eleventh Circuit Court of Appeals, No ) d) October 8, 2015 Answer Brief in Investment Corp. of Palm Beach v. Department of Business and Professional Regulation (Fourth District Court of Appeal, No. 4D ) e) October 13, 2015 Answer Brief in Burroughs v. Corey (Eleventh Circuit Court of Appeals, No ) f) ongoing briefing in State v. Gainesville Woman Care LLC (First District Court of Appeal, No. 1D ) 3. Additionally, the Florida Solicitor General s Office is preparing for oral arguments before the Supreme Court of the United States (Hurst v. Florida, No , to be held October 13, 2015), the Eleventh Circuit Court of Appeals 2

3 (Harrison v. Director, Florida Agency for Persons with Disabilities (No , to be held October 2, 2015), and the Florida Supreme Court (Department of Revenue v. American Business USA Corp., No. SC , to be held November 5, 2015). In light of this workload, State Appellees require the full 60 days to prepare their Answer Brief. 4. The undersigned has conferred with counsel for Appellants and counsel for Appellee Intervenors and is authorized to represent that they have no objection to the requested extension of 60 days. WHEREFORE, State Appellees request a 60-day extension, up to and including November 16, 2015, in which to serve their Answer Brief. Respectfully Submitted, PAMELA JO BONDI ATTORNEY GENERAL /s/ Rachel Nordby ALLEN WINSOR (FBN 16295) Solicitor General RACHEL NORDBY (FBN ) Deputy Solicitor General Office of the Attorney General The Capitol, PL-01 Tallahassee, Florida allen.winsor@myfloridalegal.com rachel.nordby@myfloridalegal.com (850) (850) (fax) 3

4 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been furnished by electronic mail on September 8, 2015 to the following counsel of record for the parties: Counsel for Appellants Ronald G. Meyer Jennifer S. Blohm Lynn C. Hearn Meyer, Brooks, Demma & Blohm, P.A. 131 N. Gadsden St. P.O. Box 1547 (32302) (850) (850) (fax) rmeyer@meyerbrookslaw.com jblohm@meyerbrookslaw.com lhearn@meyerbrookslaw.com Alice O Brien National Education Association 1201 Sixteen St. NW Washington, D.C (202) aobrien@nea.org David Strom American Federation of Teachers 555 New Jersey Ave., NW Washington, D.C dstrom@aft.org John M. West Bredhoff & Kaiser, P.L.L.C. 805 Fifteenth St. NW Ste Washington, D.C (202) jwest@bredhoff.com Pamela L. Cooper William A. Spillias Florida Education Association 213 S. Adams St. (850) (850) (fax) pam.cooper@floridaea.org will.spillias@floridaea.org Alex J. Luchenitser Americans United for Separation of Church and State 1301 K Street, NW Ste. 850, East Tower Washington, D.C luchenitser@au.org 4

5 Counsel for Appellee Intervenors Karen D. Walker Nathan A. Adams, IV Holland & Knight LLP 315 S. Calhoun Street, Suite Raoul G. Cantero White & Case LLP Southeast Financial Center, Ste South Biscayne Boulevard Miami, FL Jay P. Lefkowitz Steven J. Menashi Kirkland & Ellis, LLP 601 Lexington Avenue New York, NY Daniel J. Woodring Woodring Law Firm 203 N. Gadsden Street, Suite 1-C /s/ Rachel Nordby Attorney 5