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efta-efta00205152DOJ Data Set 9Other

From: Paul Cassell <cassell. e law.utah.edu>

From: Paul Cassell <cassell. e law.utah.edu> Cc: Brad Edwards <bedwards®pathtojustice.com> Subject: RE: Redacted Pleading Rather than Sealing the Entire Pleading Date: Thu, 01 Dec 2011 17:48:54 +0000 Importance: Normal We haven't heard back from you on the issue regarding sealing of ' n the Epstein case. (See email below sent earlier this week.) I was hoping that you (o ould get back to Brad and me quickly on this issue. As you know, we have a series of pleadings that we need to file on Monday. We are trying to understand the Government's position on sealing these pleadings. As you also know, we think there is absolutely no basis for sealing the majority of the Government's pleadings. We hope you agree so that we can move forward consensually, at least on this issue. Thank you in advance for your assistance. Paul Cassell Co-Counsel for Jane Doe #1 and Jane Doe #2 Paul G. Cassell CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential.

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DOJ Data Set 9
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EFTA 00205152
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2
Persons
4
Integrity

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From: Paul Cassell <cassell. e law.utah.edu> Cc: Brad Edwards <bedwards®pathtojustice.com> Subject: RE: Redacted Pleading Rather than Sealing the Entire Pleading Date: Thu, 01 Dec 2011 17:48:54 +0000 Importance: Normal We haven't heard back from you on the issue regarding sealing of ' n the Epstein case. (See email below sent earlier this week.) I was hoping that you (o ould get back to Brad and me quickly on this issue. As you know, we have a series of pleadings that we need to file on Monday. We are trying to understand the Government's position on sealing these pleadings. As you also know, we think there is absolutely no basis for sealing the majority of the Government's pleadings. We hope you agree so that we can move forward consensually, at least on this issue. Thank you in advance for your assistance. Paul Cassell Co-Counsel for Jane Doe #1 and Jane Doe #2 Paul G. Cassell CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential.

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From: Paul Cassell <cassell. e law.utah.edu> Cc: Brad Edwards <bedwards®pathtojustice.com> Subject: RE: Redacted Pleading Rather than Sealing the Entire Pleading Date: Thu, 01 Dec 2011 17:48:54 +0000 Importance: Normal We haven't heard back from you on the issue regarding sealing of ' n the Epstein case. (See email below sent earlier this week.) I was hoping that you (o ould get back to Brad and me quickly on this issue. As you know, we have a series of pleadings that we need to file on Monday. We are trying to understand the Government's position on sealing these pleadings. As you also know, we think there is absolutely no basis for sealing the majority of the Government's pleadings. We hope you agree so that we can move forward consensually, at least on this issue. Thank you in advance for your assistance. Paul Cassell Co-Counsel 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, 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 From: Paul Cassell Sent: Monda , November 28, 2011 2:29 PM c: ra war s Subject: RE: Redacted Pleading Rather than Sealing the Entire Pleading EFTA00205152 I am writing as co-counsel in the Jane Doe case. I understand that you are supervising the case for U.S. Attorney's Office there. I am writing to request that the Government file new, redacted copies of its currently pending motion to dismiss and motion for stay. As you may know, the Government has filed these two motions entirely under seal. Yet the vast bulk of both motions do not deal with any material that needs to be under seal. As you may know, Judge Marra has previously unsealed other pleadings in this case, recognizing the considerable public interest in the issues being discussed. As you also know, Jane Doe #1 and Jane Doe #2 have tried to work cooperatively with the Government wherever possible. For example, we earlier stipulated to proposed redactions of material proposed by Ms. Villafana to avoid disclosing information that she viewed as confidential. In light of all this, the victims are writing to inquire whether the Government would file a motion to place redacted copies of its two motions in the public court file in the case. Attached are two redacted pleadings that we believe remove all information that is properly subject to sealing to protect confidential grand jury material - but no more. Please let me know whether the Government is willing to move forward on that basis. Sincerely, Paul Cassell Co-Counsel for Jane Doe #1 and Jane Doe #2 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. EFTA00205153

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DOJ Data Set 9OtherUnknown

Subject: Re: Lack of jurisdiction in the Eleventh Circuit

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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DOJ Data Set 9OtherUnknown

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

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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