From: Paul Cassell
From: Paul Cassell To: a" 1SAFLS)" < (USAFLS)" . (USAFLS)" Cc: Brad Edwards • Subject: RE: Government's position on two motions Date: Wed, 01 Feb 2012 22:30:23 +0000 Importance: Normal Dear E, Thank you for sending the seal pleading to us electronically last weekend. We really appreciate it. We are now working on responding to your reply on the issue of remedies. As you know, the Government has placed the entire reply under seal. With all due respect, we believe that placing the entire document under seal is inappropriate. The vast majority of the issues and arguments in the pleading are not confidential. We believe that placing them under seal violates DOJ policy as well as constitutional First Amendment principles. Placing the document under seal also creates significant problems for the victims. Just as you have been consulting your colleagues in Washington, D.C., on these issues, we have been consulting with our friends in the victims' rights movement around the cou
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From: Paul Cassell To: a" 1SAFLS)" < (USAFLS)" . (USAFLS)" Cc: Brad Edwards • Subject: RE: Government's position on two motions Date: Wed, 01 Feb 2012 22:30:23 +0000 Importance: Normal Dear E, Thank you for sending the seal pleading to us electronically last weekend. We really appreciate it. We are now working on responding to your reply on the issue of remedies. As you know, the Government has placed the entire reply under seal. With all due respect, we believe that placing the entire document under seal is inappropriate. The vast majority of the issues and arguments in the pleading are not confidential. We believe that placing them under seal violates DOJ policy as well as constitutional First Amendment principles. Placing the document under seal also creates significant problems for the victims. Just as you have been consulting your colleagues in Washington, D.C., on these issues, we have been consulting with our friends in the victims' rights movement around the cou
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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
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
Filing # 35429605 E-Filed 12/11/2015 10:08:04 AM
To: "Paul Cassell"
From: To: "Paul Cassell" Cc: ' "Brad Edwards" Subject: : ovemments osition on Several Pending Issues? Still Waiting for Answer Date: Thu, 17 Mar 2011 16:56:28 +0000 Importance: Normal Paul, 1. Yesterday, I provided you with the name and phone number for OPR Acting Associate Counsel, who received your December 10, 2010 letter to Mr. Ferrer, asking for an investigation of the Jeffrey Epstein prosecution. 2. The government will not be making initial disclosures to plaintiffs, because we do not believe Fed.R.Civ.P. 26 applies to this matter. 3. The CVRA applies to the criminal case which has been filed in district court, where an individual is deemed to be a "victim," not any civil litigation which may be initiated to enforce those claimed rights. We do not believe there is any right to discovery in this case. Moreover, we do not believe that whatever Kenneth Starr or Lilly Ann Sanchez may have said to this office, or what this office said to Kenneth Starr or Lilly Ann S
Filing # 31897743 E-Filed 09/10/2015 12:44:35 PM
From: Brad Edwards
From: Brad Edwards To: Cc: Paul Cassell Subject: Re: Rescheduling Settlement Conference - bad date Date: Sat, 25 Jun 2016 20:39:34 +0000 Importance: Normal Inline-Images: image001.png; image002.png I will forward everything to Paul. is calling me Tuesday. I will use that time to relay everything to her and see where we are then. Sent from my iPhone On Jun 25, 2016, at 4:23 PM, wrote: Hi Paul — Thank you for your email. July 5th is bad for us, too, but I saw Judge Brannon to sign some search warrants yesterday and, although we didn't talk about this case, he mentioned how full his schedule was. I don't know that he is going to be inclined to move it, especially in light of Jane Doe #1's status. I am wondering if you think it is possible for us to finalize things without going back to court? Brad now has our complete packet and I think if we can get things resolved over the next week, then we can take the settlement conference off the calendar and move on to asking Judg
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