EFTA00205136.pdf

From: Paul Cassell <[email protected]> Brad Edwards ra patntojusttce.com Subject: RE: government position? Date: Fri, 03 Feb 2012 00:43:21 +0000 Importance: Normal Sorry to rush you, but following up on our email from a couple of days ago, Brad and I are hoping to file tomorrow (1) Our motion for order directing government to file redacted, unsealed pleadings in the public court file (all three of your sealed pleadings); and (2) A motion for the court to deny the motion to dismiss without requiring additional pleadings from us or, at a minimum, ti grant leave to file a sur-reply (we propose that our brief be of the same length as yours and due 4 weeks after the court rules on our motion (1) above). I know there may be a "clearance" process there on this case, but hoping you can give us a position by, say, noon Friday? Thanks in advance for your help. Paul Cassell Co-counsel for Jane Doe ttl and Jane Doe #2 Paul G. Cassell 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: Friday, January 27, 2012 5:14 PM To: Paul Cassell; Brad Edwards Subject: Reply re Motion to Dismiss Hi Paul and Brad — I apologize, I didn't get Ed's email because I have been in trial prep. Here is the reply without the attachments. Brad should have received the corn lete documents today in the mail. The attachments are the complaints and amended complaints from the state court litigation. I have encrypted the file because of the 6(e) material. I will send the password to Brad separately. Paul — if you want to give me a number where I can send you a text, I can text to you or leave you a voicemail with the EFTA00205136 password. EFTA00205137