To: Paul Cassell <cassellp@law.utah.edu>, "

From: To: Paul Cassell <cassellp@law.utah.edu>, " Cc: Subject: RE: Voluntary Production of Materials - three ideas Date: Thu, 19 Jan 2012 00:47:46 +0000 Importance: Normal Dear Paul and Brad: Thank you for your email. Here is where we are on your three requests. Your first request asks for the emails from Epstein's lawyers to attorneys within the U.S. Attorney's Office regarding the non-prosecution agreement. Our understanding regarding the status of the current litigation is that Judge Marra currently has motions pending before him addressing: (1) whether you can use the emails that you have already received from other civil cases in this litigation and (2) whether any work product privilege or other privilege applies to the additional email communications that you seek. Given the status of those motions, it would be imprudent and inappropriate to voluntarily produce the materials to you prior to receiving the Court's ruling on those pending issues. We will, however, un