EFTA00211125.pdf

From: ' (USAFLS)" To: UWE. (USAFLS)" (USAFLS)" Subject: RE: Tracking down materials Date: Thu, 29 Sep 2016 18:57:10 +0000 Importance: Normal Inline-Images: image001.png; image002.jpg I can talk at 4 or 4:30. I'm on the road after 5:30 today and virtually all day tomorrow. From: (USAFLS) Sent: Thursday, September 29, 2016 12:59 PM To: (USAFLS) < ); (USAFLS) < > Subject: FW: Tracking down materials Can we discuss tomorrow afternoon? Or after 4:00 today? Thanks. Assistant U.S. Attorney Southern District of Florida From: Brad Edwards [mailto: Sent: Wednesday, September 28, 2016 12:33 PM To: . (USAFLS) ; Paul Cassell Cc: (USAFLS) >; (USAFLS). Subject: RE: Tracking down materials Yes, I believe the records were served August 31st. I don't have the requests in front of me, but rather than search every government computer I think you would only need to search the computers (and emails) of the various people specifically named in the requests, along with Nezbitt's and Jason's (if those names were not provided). If there is a central server, especially for the intranet FBI system then that would probably be a place to search as well. As for the requests themselves, they were drafted fairly narrowly given the information we have. If there is something about the requests that is making the search particularly difficult, let me know and I will see what more information I can give you to help you locate exactly what we are looking for. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Brad Edwards Board Certified Trial Attorney EFTA00211125  www.pattitojustice.com 0001‘100t From: (USAFLS) imailto: Sent: Wednesday, September 28, 2016 11:33 AM To: Paul Cassell •,: > Brad Edwards Cc:-(USAFLS)' (USAFLS) Subject: RE: Tracking down materials Hi Paul —1 hope that you are well. I have been out of the office for a bit, but • and have been working on your requests. has been in contact with the FBI and they are checking on whether there are responsive emails and how we go about accessing any, should they exist. I know that we had some conversation about narrowing the requests, but we believe that you need to try to narrow them in writing so that we can determine whether we need to apply to the Court to quash or limit the requests. As written, and even following the discussion, they are so broad and vague that we do not feel that we can respond. Some seem to call for a search of every government computer file, which would be impossible. Do you want to try to be more specific and, in the meantime we will continue our efforts with the FBI and with items that are fairly specific (e.g., you specifically refer to l=, which is something we have been and can continue to look into)? The certificates of service specify different dates, but my records show that they were served on August 31St, is that consistent with your records? Thanks so much. Assistant U.S. Attorney Southern District ofFlorida From: Paul Cassell imailto: Sent: Tuesday, September 27, 2016 3:18 PM To: 'Brad Edwards' . (USAFLS) Cc: (USAFLS) ; (USAFLS) < > Subject: RE: Tracking down materials Hey M, Just wanted to touch base and see how things are coming collecting the information that we talked about on the phone on September 2, if I recall correctly? As mentioned, I hopefully gave you precise enough information that finding the materials would not have been time consuming on your end. Just wanted to see if you had any more questions about that. Brad and I can assist if needed. Paul Cassell for Jane Doe 1 and 2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law EFTA00211126 University Distinguished Professor of Law You can access my publications on http://ssm.com/author=30160 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: Paul Cassell Sent: Wednesday, August 31, 2016 3:28 PM To: Brad Edwards .c. ; (USAFLS) Cc: (USAFLS) (USAFLS) •ca Subject: RE: Conf call re scheduling and discovery? I free at that time on Friday — 3 PM Florida time, 1 PM Utah time. Glad to chat. Please call my cell, at . PC Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law University Distinguished Professor of Law You can access my publications on http://ssm.com/author=30160 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: Brad Edwards [mailto: Sent: Wednesday, August 31, 2016 3:26 PM To: . (USAFLS) Cc: Paul Cassell .c :,•; (USAFLS) (USAFLS) Subject: Re: Conf call re scheduling and discovery? I have a deposition Friday afternoon but don't need to be on the call if Paul is free. Sent from my iPhone On Aug 31, 2016, at 5:15 PM, . (USAFLS) wrote: Hi Brad and Paul — Can we do a conference call to talk about the schedule? I am totally booked tomorrow and has a mediation on Friday morning, so I was hoping we could chat at 3:00 on Friday. Please let me know if that works and I will set up a conference line. Thanks. EFTA00211127 Assistant U.S. Attorney Southern District of Florida EFTA00211128