EFTA00207929.pdf

From: Paul Cassell <[email protected]> To: Cc: Brad Edwards <[email protected]> Subject: RE: extra pages Date: Sun, 04 Dec 2011 18:55:18 +0000 Importance: Normal Heys, and Ed, Sorry I had to leave the call early Friday. Meant to check with you on this then. I am working with Brad to finalize our pleadings to be filed on Monday in response to the motion to dismiss. We are filing an unsealed pleading (that does not discuss grand jury material) as well as a sealed pleading (that discusses only the grand jury material and related issues). The unseal pleading is 24 pages long and the sealed pleading is 7 pages long. We also have a response to the motion to stay which is well under the 20 page limit. Any objection to a motion for the extra pages (4 + 7, although I'm not sure whether we count the 7) to respond to your motion to dismiss? Thanks for your help on getting back to us. PC Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Quinney College of Law at the University of Utah CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. From- AA. ilmetnr NA PI CI filevIrr I eerlinAni arnd Sent: Thursday, December 01, 2011 3:23 PM To: Paul Cassel /1 TO a CI CV. n TO A CT Cot Cc: Brad Edwards Subject: RE: Conference call 11:15 AM Florida time - Friday Paul, We will take care of the arrangements for tomorrow at 11:15 a.m. Thanks. Dexter From: Paul enc.p11 mailto:cassella©law.utah.edu] Sent: Thursday, December 01, 2011 4:59 PM To: ) Cc: Brad Edwards; I•sevastalaSolgoehsia). Subject: RE: Conference call 11:15 AM Florida time - Friday Hi all, Does 11:15 AM Florida time on Friday work? EFTA00207929 If so, please call my cell phone (801) 2014271 as well as Brad — Ed/Dexter can y'all initiate the conference call or set up a call in number? Looking forward to chatting. PC Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. Sent: To: S Cc: B Subje Hi everyone — Sony, I am having a very busy duty week. Tomorrow I have court at 9:00 probably until 11:00 and then again from 3:00 until 5:00. I have a debriefing at 1:00, but I should be able to step out after 1:30. So, 11:15 or 1:30 are best for me, but your schedules take priority. From CA. lr A rt Sent: Thursday, December 01, 2011 3:52 PM To: Paul Cassell Cc: Brad Edwards; Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? Unfortunately, that doesn't work for us today. Can we set up a time for tomorrow? Counselor to the United States Attorney United States Attorney's Office 99 N.E. 4th Street, Suite 800 Miami, FL 33132 Telephone: 305.961.9057 EFTA00207930 ----Original Message-- From: Paul Cassell [mailto:cassella©law.utah.edu]cznailtoimailto:[email protected]]> Sent: Thursday, December 01, 2011 2:22 PM To: Cc: Brad Edwards Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? Hi wand Co., Thanks for the call. Sony I was on the other line. Can we set up a time certain? That way Brad can participate. He is in a depo until 4:30, but should be free at 5 PM your time today (Thursday). Does that work? Looking forward to chatting. PC Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Quinney College of Law at the University of Utah CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. ----Original Message--- EFTA00207931 From: Paul Cassell Sent: Thursday, December 01, 2011 11:25 AM To: Cc: 'Brad Edwards' Subject: RE: Discovery Issues in Epstein Dear Mr. eenehre We will shortly be filing a motion to compel Government responses to our discovery requests — discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay. But if the Government's position is rejected on those motions, then the next issue is what discovery can we expect to receive from the Government. If the motions are denied, will the Government voluntarily produce anything to us? Will the government at least agree to produce the following: (1) The Government's initial disclosures pursuant to Fed. R. Civ. P. 26; (2) Answers to all of the victims' requests for admission; (3) All documents, correspondence, and other information that the Government distributed to persons or entities outside of the federal Government or received from persons or entities outside of the federal government; and (4) All documents, correspondence, and other information covered by the victims' discovery request that is not subject to a claim of privilege. And, for all other information withheld, will the Government agree to produce a document•by-document privilege log, as required by the local rules? Thanks for your help on these questions and Brad and I have. Sincerely, Paul Cassell Co•Counsel for Jane Doe #1 and Jane Doe rt2 Paul G. Cassell EFTA00207932 Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. EFTA00207933