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From: Paul Cassel

From: Paul Cassel To: Cc: Brad Edwards Subject: RE: Letter to Ferrer Date: Fri, 30 Sep 2011 03:30:20 +0000 Importance: Normal Attachments: letter-to-usattomey-sept29-2011.pdf Hi Thanks for getting back to us so promptly. While we strenuously disagree with your assertions, we appreciate you letting us know quickly. Brad and I fed-exed the attached letter to US Attorney Ferrer today. We are sending cc's to you an via snail mail. I thought you might want a courtesy copy quickly. Paul Cassell for Jane Doe #1 and Jane Doe #2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law J. Ouinnev Colle e of Law at the University of Utah CONFIDENTIAL: This electronic message - along with any/all attachments - is confidenital. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have

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DOJ Data Set 9
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EFTA 00205181
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2
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4
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From: Paul Cassel To: Cc: Brad Edwards Subject: RE: Letter to Ferrer Date: Fri, 30 Sep 2011 03:30:20 +0000 Importance: Normal Attachments: letter-to-usattomey-sept29-2011.pdf Hi Thanks for getting back to us so promptly. While we strenuously disagree with your assertions, we appreciate you letting us know quickly. Brad and I fed-exed the attached letter to US Attorney Ferrer today. We are sending cc's to you an via snail mail. I thought you might want a courtesy copy quickly. Paul Cassell for Jane Doe #1 and Jane Doe #2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law J. Ouinnev Colle e of Law at the University of Utah CONFIDENTIAL: This electronic message - along with any/all attachments - is confidenital. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have

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From: Paul Cassel To: Cc: Brad Edwards Subject: RE: Letter to Ferrer Date: Fri, 30 Sep 2011 03:30:20 +0000 Importance: Normal Attachments: letter-to-usattomey-sept29-2011.pdf Hi Thanks for getting back to us so promptly. While we strenuously disagree with your assertions, we appreciate you letting us know quickly. Brad and I fed-exed the attached letter to US Attorney Ferrer today. We are sending cc's to you an via snail mail. I thought you might want a courtesy copy quickly. Paul Cassell for Jane Doe #1 and Jane Doe #2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law J. Ouinnev Colle e of Law at the University of Utah CONFIDENTIAL: This electronic message - along with any/all attachments - is confidenital. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responible 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. From Sent: urs ay, e em er To: Paul Cassell; Cc: Brad Edwards Subject: RE: Any voluntary production of documents? Dear Paul and Brad: Your request is still under advisement, but I am going to be out tomorrow and I wanted to respect Paul's request for a response by Friday. After conferring with from our review of your request, it appears that the documents that you have requested fall within the attorney-client, work product, and other privileges and many are covered by the secrecy rules of Fed. R. Crim. P. 6(e). Accordingly, we cannot agree to voluntarily provide them to you. If we receive any different direction, I will let you know promptly. EFTA00205181 Thank you. Assistant Attorney Original Message From: Paul Cassell [ Sent: Wednesday, September 28, 2011 11:50 AM To: Cc Brad Edwards Subject: Any voluntary production of documents? Dear As you know, Judge Marra has now ordered discovery in this case. We are in the process of formulating our discovery requests. We are writing to inquire as to whether the Government will voluntarily produce any documents to us. We understand that briefing is still on-going regarding the U.S. Attorney's correspondence. But there are other items that are plainly relevant that are not subject to that litigation, including (but not limited to): the "pros memo" in this case; the "case file" in this case; the draft indictments; the draft plea agreements and non-prosecution agreements; the draft CVRA notices to victims; information obtained by OPR as part of its investigation/inquiry; and correspondence or communications between the USAO and the FBI regarding this case, including crime victims issues. It would obviously help us to narrow down our document production request if you would voluntarily provide some of this information to us. We also continue to believe that you are obligated to provide all of this information to us as part of (among other things) (1) the Justice Department's "best efforts" requirements under the CVRA, particularly now that Judge Marra has rejected your position that the CVRA was never triggered in this case; and (2) the Justice Department's obligation to afford victims their right to be "treated with fairness." Thanks in advance for letting us know whether we can receive any voluntary production of documents relevant to our pending summary judgment motion. The favor of a reply by the close of business this Friday would be greatly appreciated. Brad Edwards and Paul Cassell for Jane Doe #1 and Jane Doe #2 Paul G. Cassell Ronald N. Bo ce Presidential Professor of Criminal Law S.J. • uinne Colle e of Law at the University of Utah 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. EFTA00205182

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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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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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