IN THE SUPREME COURT OF THE STATE OF FLORIDA CASE NO. SC
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1 IN THE SUPREME COURT OF THE STATE OF FLORIDA CASE NO. SC ALBERT GORE, Jr., Nominee of the Democratic Party of the United States for President of the United States, JOSEPH I. LIEBERMAN, Nominee of the Democratic Party of the United States for Vice President of the United States, Appellants, vs. KATHERINE HARRIS, as SECRETARY OF STATE STATE OF FLORIDA, SECRETARY OF AGRICULTURE BOB CRAWFORD, SECRETARY OF STATE KATHERINE HARRIS AND L. CLAYTON ROBERTS, DIRECTOR, DIVISION OF ELECTIONS, individually as members of as THE FLORIDA ELECTIONS CANVASSING COMMISSION, THE MIAMI-DADE COUNTY CANVASSING BOARD, LAWRENCE D. KING, MYRIAM LEHR DAVID C. LEAHY as members of as THE MIAMI-DADE COUNTY CANVASSING BOARD, DAVID C. LEAHY, individually as Supervisor of Elections, THE NASSAU COUNTY CANVASSING BOARD, ROBERT E. WILLIAMS, SHIRLEY N. KING, AND DAVID HOWARD (or, in the alternative, MARIANNE P. MARSHALL), as members of as the NASSAU COUNTY CANVASSING BOARD,
2 SHIRLEY N. KING, individually as Supervisor of Elections, THE PALM BEACH COUNTY CANVASSING BOARD, THERESA LEPORE, CHARLES E. BURTON AND CAROL ROBERTS, as members of as the PALM BEACH COUNTY CANVASSING BOARD, THERESA LEPORE, individually as Supervisor of Elections, GEORGE W. BUSH, Nominee of the Republican Party of the United States for President of the United States RICHARD CHENEY, Nominee of the Republican Party of the United States for Vice President of the United States, Appellees, _ CASE NO. ALBERT GORE, Jr., Nominee of the Democratic Party of the United States for President of the United States, JOSEPH I. LIEBERMAN, Nominee of the Democratic Party of the United States for Vice President of the United States, Petitioners, vs. KATHERINE HARRIS, as SECRETARY OF STATE STATE OF FLORIDA, SECRETARY OF AGRICULTURE BOB CRAWFORD, SECRETARY OF STATE KATHERINE HARRIS AND L. CLAYTON ROBERTS, DIRECTOR, DIVISION OF ELECTIONS, individually as members of as THE FLORIDA ELECTIONS CANVASSING COMMISSION,
3 Respondents. MOTION OF APPELLANTS/PETITINOERS TO EXPAND INITIAL BRIEF The Appellants/Petitioners move, pursuant to Florida Rules of Appellate Procedure 9.210(a)(5) 9.300, to exp the length of the Initial Brief to 65 pages. The issues in this case are many complex. The outcome of this case will likely determine who is the next President of the United States. The parties disagree vehemently on a multitude of issues. Each issue must be briefed. The briefing schedule in this matter has been compressed because of the need for quick resolution recognized by all parties the Court. The parties are filing briefs simultaneously at noon, December 6, 2000, are not filing Reply Briefs. In an ordinary case Florida Rule of Appellate Procedure 9.210(a) would permit Appellants/Petitioners to file an Initial Brief of 50 pages a Reply Brief of 15 pages, totaling 65 pages Appellants/Petitioners have made every effort to condense the Initial Brief. Granting the requested relief would serve the ends of justice. Appellants/Petitioners would not object to Appellees/Respondents receiving authority to file an exped Initial Brief. Respectfully submitted this day of December John D. C. Newton, II Florida Bar No.: Berger Davis & Singerman 215 South Monroe Street, Suite 705 Tallahassee, Florida Telephone: 850/ Facsimile: 850/ CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing has been furnished by United States mail, h delivery or facsimile
4 transmission this day of December 2000 to the following Barry Richard Greenberg Traurig 101 East College Avenue Tallahassee, FL for Governor Bush R. Frank Myers Messer Caparello & Self 215 South Monroe Street, Suite 701 Tallahassee, Florida for Intervenor Named West Florida Voters Deborah Kearney, General Counsel Florida Department of State 400 South Monroe Street, PL 02 Tallahassee, FL for Secretary Katherine Harris the Elections Canvassing Committee Donna E. Blanton Joseph Klock Steel Hector & Davis 215 South Monroe Street, Suite 601 Tallahassee, FL for Secretary Katherine Harris the Elections Canvassing Committee Tucker Ronzetti Assistant County Attorney 111 N.W. 1 st Street Miami, FL for Miami-Dade County Canvassing Board Ben Ginsburg
5 State Republican Headquarters 420 West Jefferson Street Tallahassee, FL for the Republican Party Craig Meyer Florida Department of Agriculture Consumer Services The Capitol Tallahassee, FL Andrew McMahon Palm Beach County Attorney Office 301 N Olive Avenue, Suite 601 West Palm Beach, FL for Palm Beach Canvassing Board Bruce Rogow Bruce S. Rogow, P.A. 500 East Broward Boulevard, Suite 1930 Ft. Lauderdale, Florida for Palm Beach Canvassing Board Michael S. Mullin 191 Nassau Place Yulee, Florida for Nassau County Canvassing Board Terrell C. Madigan McFarlain Wiley Cassedy & Jones 215 South Monroe Street, Suite 600 Tallahassee, FL for Intervenor Butler John D. C. Newton, II Attorney
IN THE SUPREME COURT OF FLORIDA CASE NO. SC PALM BEACH COUNTY CANVASSING BOARD, Petitioner, vs.
IN THE SUPREME COURT OF FLORIDA CASE NO. SC 00-2346 PALM BEACH COUNTY CANVASSING BOARD, Petitioner, vs. KATHERINE HARRIS, as Secretary of State, State of Florida, and ROBERT A. BUTTERWORTH, as Attorney
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Supreme Court of Florida
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Supreme Court of Florida
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OFFICE OF THE ATTORNEY GENERAL PL-01 The Capitol Tallahassee, FL 32399-1050 PAM BONDI Phone (850) 414-3300 Fax (850) 488-4483 ATTORNEYGENERAL http://www.myfloridalegal.com STATE OF FLORIDA INSTRUCTION
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SUPREME COURT OF THE UNITED STATES
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