From: '
From: ' (USAFLS)" To: (USAFLS)" Subject: RE: CVRA case Date: Tue, 12 Oct 2010 20:49:04 +0000 Importance: Normal I agree with your statement. I thought that you had framed our initial response to their complaint in terms of "mootness," but your response has reminded me that you didn't say it was moot, just that the Court had no authority to set aside the non-prosecution agreement. I will watch CM/ECF while you are at the NAC. Assistant U.S. Attorne Fax From: (USAFLS) Sent: Tuesday, October 12, 2010 4:46 PM To: . (USAFLS) Subject: RE: CVRA case A moot case is one where there is no longer any dispute for which the court can grant relief. If their previous conduct is any indication, plaintiffs will probably assert that the CVRA obligated the government to consult with them prior to entering into the non-prosecution agreement. They seem to be resigned to the fact that the court cannot or will not set aside the non-prosecution agreement, since the relief plaintiffs
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From: ' (USAFLS)" To: (USAFLS)" Subject: RE: CVRA case Date: Tue, 12 Oct 2010 20:49:04 +0000 Importance: Normal I agree with your statement. I thought that you had framed our initial response to their complaint in terms of "mootness," but your response has reminded me that you didn't say it was moot, just that the Court had no authority to set aside the non-prosecution agreement. I will watch CM/ECF while you are at the NAC. Assistant U.S. Attorne Fax From: (USAFLS) Sent: Tuesday, October 12, 2010 4:46 PM To: . (USAFLS) Subject: RE: CVRA case A moot case is one where there is no longer any dispute for which the court can grant relief. If their previous conduct is any indication, plaintiffs will probably assert that the CVRA obligated the government to consult with them prior to entering into the non-prosecution agreement. They seem to be resigned to the fact that the court cannot or will not set aside the non-prosecution agreement, since the relief plaintiffs
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“...helping the case to progress smoothly. Sincerely, Paul Cassell Counsel for Jane Does Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J....”
Paul Cassell“...FW: CVRA case This is plaintiffs' response to the order to show cause. From: Paul Cassell [mailto Sent: Tuesda October 12, 2010 3:47 PM To: (USAFLS) Cc: Brad Edwards...”
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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
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
Filing # 31897743 E-Filed 09/10/2015 12:44:35 PM
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
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
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CI V-Marra/Matthewman JANE DOE # I and JANE DOE #2, Petitioners, I UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "government") hereby responds to Jane Doe #1 and Jane Doe #2's First Request for Admissions to the Government Regarding Questions Relevant to Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for Admissions"), and states as follows:' I. The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses. Except as otherwise admitted above, the government denies Request No. I. The government's res
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