UNITED STATES OF AMERICA
The United States files the within Motion For Leave to File Instanter Enlarged Response of the United States to Motion of Defendant Weil for Release on Bail Pending Appeal. The local rules of the Southern District of Florida limit a Response to twenty pages, without prior leave of the Court. In this case, there is good cause shown for the enlarged Response.
It takes only a paragraph or two to raise an issue. To respond to an issue, however, often takes many pages, regardless of the issue's merits. Weil raises eight issues in the instant motion. Some of the issues have subparts. Many of the issues and their subparts involve detailed legal and factual questions even though it is ultimately clear how they should be resolved. To offer a considered response to the each of Weil's allegations takes more than twenty pages.
In short, the purpose of the enlarged Response is not to waste the Court's time, but to aid it in deciding the pending motion.
Accordingly, the United States respectfully requests that this Court grant the within Motion.