EFTA00211511.pdf

Subject: RE: RE Any opposition to excusing Jane Doe 2? Date: Fri, 22 Apr 2016 14:50:53 +0000 Importance: Normal Hi Paul and Brad: We do not oppose the motion so long as it includes language that Jane Doe 2 has authorized Jane Doe 1 to act on her behalf and had agreed to abide by the decisions made by Jane Doe 1 at the mediation. I know that you are out of town, but we would like Jane Doe 2 to sign something herself to that effect. If you can't get that done today, then we do not oppose the motion so long as something signed by Jane Doe 2 is filed with the Court at least a week before the mediation. Thank you both! From: Paul Cassell [mailto Sent: Friday, April 22, 2016 8:34 AM To: I ); Brad Edwards ( Subject: RE Any opposition to excusing Jane Doe 2? Hey =, Brad and I are preparing to file today not only the pleading regarding Epstein's attendance at the mediation (shown to you earlier) but also a separate pleading seeking to excuse Jane Doe 2 from the personal attendance requirement. We would like to indicate that this motion is unopposed. See the text of the motion below. Thanks in advance for giving us your position. Paul and Brad for Jane Doe 2 *** COMES NOW Jane Doe No. 2 (the "victims"), by and through undersigned counsel, to request that she be excused from the upcoming court-ordered mediation session in this case. Jane Doe 2 is aware that, ordinarily, the personal attendance of all parties to a case is required. The obvious purpose of that requirement is to insure that, if possible, the mediation is successful. In this case, Jane Doe 2 has agreed that, if a mediated resolution is reached with Jane Doe 1, that resolution will be acceptable to her as well. She will also be available by telephone should any unanticipated need arise. Accordingly, her personal attendance at the mediation will not be required to produce a successful mediation and she should not be required to personally attend. EFTA00211511  WHEREFORE, Jane Doe 2 asks to be excused from personal attendance requirement of the pending mediation. 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, 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. Professor Cassell is admitted to the Utah State Bar, but not the bars of other states. Thank you. From: Sent: Monday, April 18 2016 6:33 PM To: Brad Edwards ; Paul Cassell Subject: Checking in on the motion for writ Hi Brad and Paul — I noticed that the motion for writ hasn't been filed yet. The Marshals have to arrange to travel to Tampa and back plus do all the legwork to have the Sheriff release the prisoner. In other words, you need to file the motion asap for us to keep the May date. The cases say that the writ can be denied if it is untimely — even if the prisoner is the plaintiff in the suit. Thanks. EFTA00211512