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(USAFLS)" <=IMIIM>

From: (USAFLS)" <=IMIIM> To: Paul Cassell alla> Cc: aLS)" Subject: RE: Doe USAO Date: Tue, 15 Nov 2011 00:37:05 +0000 Importance: Normal Brad Edwards Paul and Brad, We have no objections as to the extension of time until December 5. Let me check with my colleagues on the other issues, and I will let you know tomorrow. Thanks. Original Message From: Paul Cassell [mailto: Sent: Monda November 14, 2011 7:34 PM To: USAFLS Cc: . (USAFLS); Brad Edwards Subject: RE: Doe USAO Hey and =, I. As you may know, Brad is buried in a three-week jury trial, so I have not been able to consult with him at any length about the pending motion to dismiss and to stay. I also have another brief due on next Wednesday, as well as long-scheduled vacation the week of Thanksgiving. In light of all this, I am writing to inquire about the Government's position concerning a ten-day extension of the due date to respond to the motion to dismiss until December 5. 2. I noticed that you have

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DOJ Data Set 9
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EFTA 00204929
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From: (USAFLS)" <=IMIIM> To: Paul Cassell alla> Cc: aLS)" Subject: RE: Doe USAO Date: Tue, 15 Nov 2011 00:37:05 +0000 Importance: Normal Brad Edwards Paul and Brad, We have no objections as to the extension of time until December 5. Let me check with my colleagues on the other issues, and I will let you know tomorrow. Thanks. Original Message From: Paul Cassell [mailto: Sent: Monda November 14, 2011 7:34 PM To: USAFLS Cc: . (USAFLS); Brad Edwards Subject: RE: Doe USAO Hey and =, I. As you may know, Brad is buried in a three-week jury trial, so I have not been able to consult with him at any length about the pending motion to dismiss and to stay. I also have another brief due on next Wednesday, as well as long-scheduled vacation the week of Thanksgiving. In light of all this, I am writing to inquire about the Government's position concerning a ten-day extension of the due date to respond to the motion to dismiss until December 5. 2. I noticed that you have

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From: (USAFLS)" <=IMIIM> To: Paul Cassell alla> Cc: aLS)" Subject: RE: Doe USAO Date: Tue, 15 Nov 2011 00:37:05 +0000 Importance: Normal Brad Edwards Paul and Brad, We have no objections as to the extension of time until December 5. Let me check with my colleagues on the other issues, and I will let you know tomorrow. Thanks. Original Message From: Paul Cassell [mailto: Sent: Monda November 14, 2011 7:34 PM To: USAFLS Cc: . (USAFLS); Brad Edwards Subject: RE: Doe USAO Hey and =, I. As you may know, Brad is buried in a three-week jury trial, so I have not been able to consult with him at any length about the pending motion to dismiss and to stay. I also have another brief due on next Wednesday, as well as long-scheduled vacation the week of Thanksgiving. In light of all this, I am writing to inquire about the Government's position concerning a ten-day extension of the due date to respond to the motion to dismiss until December 5. 2. I noticed that you have filed two pleadings entirely under seal - your motion to dismiss and your motion to stay. And yet the vast bulk of both motions do not involve any secret grand jury material and thus (in my view) there is little reason for the vast bulk of the pleadings to be under seal. Are you willing to file redacted pleadings in the public court file? 3. If the answer to question 2 is no, what is your position on a motion from the victims asking for the court to direct the Government to file redacted pleadings in the public court file, redacting only the secret grand jury information? 4. It is our view that a bland motion for extension of time would not need to be filed under seal, because it would not disclose any grand jury materials. Here is the draft of our motion for extension of time, which we are not planning to file under seal. Please advise if you have any concerns. JANE DOE #1 AND JANE DOE #2'S UNOPPOSED MOTION FOR 10-DAY EXTENSION OF TIME TO RESPONSE TO GOVERNMENTS MOTION TO DISMISS AND MOTION FOR STAY OF DISCOVERY COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to file an unopposed motion for extension of time to respond to the Government's motion to dismiss and motion to stay proceedings. The victims' response to these two motions is currently due on Friday, November 25, 2011 - the Friday immediately following Thanksgiving. One of the victims' counsel, Bradley J. Edwards, has been in (and continues to be in) a three-week jury trial that has prevented him from turning to the pending motion. The other of the victims' counsel, Paul G. Cassell, has a brief due in the Fifth Circuit on November 23, 2011, and also long- scheduled vacation the week of Thanksgiving. Accordingly, victims counsel seek a 10-day extension to Monday, EFTA00204929 December 5, 2011, to file their responses to the Government's two pending motions. Counsel have conferred and the Government does not oppose the motion. 5. I notice in the court file that the Court entered two orders on November 9, 2011. These are sealed orders and we have not received notice of the orders. We are assuming that these are court orders granting your motion to file under seal. If they are something else, we would of course be concerned about ex parte motion practice. If they are granting the motions to file under seal, I wonder why we didn't consult about the extent of the sealing on the phone last week -- it does seem like the Government has gone overboard on sealing here, but I am hopeful that you will agree to filing redacted pleadings and obviate any problem. Thanks for your help on these questions/issues. Paul Casssell Co-Counsel for Jane Doe #1 and Jane Doe #2 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. EFTA00204930

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DOJ Data Set 9OtherUnknown

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Subject: Re: Lack of jurisdiction in the Eleventh Circuit Date: Fri, 28 Jun 2013 16:37:07 +0000 Importance: Normal It has been sent. Thanks. On Jun 28, 2013, at 12:09 PM, "Paul Cassell" <cassellp@law.utah.edu> wrote: > Could you pass along our pleading to whoever else in the Department is considering how to proceed on Epstein's interlocutory appeal? We believe our pleading makes compelling arguments that the Eleventh Circuit lacks jurisdiction, at this time, over any such appeal. Thanks! > Brad Edwards and Paul Cassell for Jane Doe #1 and Jane Doe #2 > Paul G. Cassell > Ronald N. Boyce Presidential Professor of Criminal Law > S.J. Quinney College of Law at the University of Utah > 332 South 1400 East, Room 101 Salt Lake City, UT 84112-0730 > Voice: 801-585-5202 Fax: 801-581-6897 Email: cassellp@law.utah.edu > http://www.law.utah.edu/profilesldefault.asp?PersonlD=57&name=Cassell,Paul > You can access my publications on http://ssm.corn/author=30160 > CONFIDENTIAL: This e

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From: ' (USAFLS)" To: >, ' (USAFLS)" Subject: RE: Motion to Compel and S.J. Briefing Schedule Date: Wed, 08 Mar 2017 19:38:15 +0000 Importance: Normal Hi I.— You can get me on the line once calls in. I will be at my desk — 41047 A. Vi&faller Assistant U.S. Attorney Southern District of Florida From: M, (USAFLS) Sent: Wednesday, March 08, 2017 2:11 PM To:a (USAFLS) < Cc:a MI I. (USAFLS) Subject: Re: Motion to Compel and Si. Briefing Schedule I am out of class at 5:15 pm. What number shall I call? Sent from my iPhone c On Mar 8, 2017, at 11:56, a, (USAFLS) > wrote: Can we talk later this afternoon? Begin forwarded message: From: Paul Cassell <a> Date: March 8, 2017 at 8:51:03 AM EST To: "Brad Edwards (USAFLS)" Cc: " I. (USAFLS)" '`= > (USAFLS)" Subject: RE: Motion to Compel and S.J. Briefing Schedule Dear I'm writing to express some concerns about the Government's recent response to our most recent discovery requests and to request a stipulated bri

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Subjec

Fr • < > Subjec :Deliberative t Process ec aratton rom am Justice - equest or wo ee xtension Date: Fri, 20 Sep 2013 17:59:47 +0000 Importance: Normal We have no objection, provided we get the following accommodation, which you already anticipated. We would request that your motion for extension of time give us an extension on our reply document, such that our reply would be due 10 days after the main Justice Department declaration that will be coming in two weeks. If you would include such language as well in any proposed order, saving us (and the court) drafting time, that would be very much appreciated. Paul Cassell and Brad Edwards for Jane Doe #1 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, you may not use, disseminate, distribute or copy this communication. If you have received this message

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Farmer, Jaffe, Weissing,

Farmer, Jaffe, Weissing, Edwards, Fistos £t Lehrman, P.L. 'Ovid Pam ftoisl pet WWW.PATITTOJUSTKE.COM 425 North Andrews Avenue • Suite 2 Fort Lauderdale, Florida 33301 4 00 "ti e 6.‘ tk i r atire CalkAllfle alvdtr aIINNEV rar ,NYTTENNINIP PITNEY 'OWES 02 !F $003 , 50 0 000i3V, wit JAN 2i 2,2!3 .a4P En M ZIP t20-12E 3330 Dexter Lee A. Marie Villafatia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 EFTA00191396 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, 1. UNITED STATES, Respondent. SEALED DOCUMENT EFTA00191397 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, UNITED STATES, Respondent. SEALED DOCUMENT MOTION TO SEAL Petitioners Jane Doc No. 1 and Jane Doe No. 2, joined by movants Jane Doe No. 3 and Jane Doe No. 4, move to file the attached pleading and supporti

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From: Paul Cassell •ci To: "IN (USAFLS)" ' Cc: , • (USAFLS)" USAFLS)" >, Brad Edwards Subject: RE: Judge Marra's Order Granting the Victims Motion to Compel Discovery Within 30 Days Date: Tue, 25 Jun 2013 00:46:56 +0000 Importance: Normal Attachments: ORDER-omnibus-wrapup.pdf [tried to send this earlier, but it may not have gone out] Dear We haven't seen the sealed order granting the Government's motion for stay either. (Have you?). But, in any event, Judge Marra's order on June 19, 2013 (DE 190) specifically stated that "The petitioners' motion to compel discovery from the Government [DE 130] is GRANTED. Within THIRTY (30) DAYS from the date of entry of this order, the Government shall . . . [produce various discovery]." For your convenience, I attach a copy of DE 190 ordering the Government to produce discovery within 30 days. So we are expecting to see you produce the bulk of our discovery on July 19, 2013, as specifically directed in DE 190 which granted our mo

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EFTA00013595

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