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efta-efta00206877DOJ Data Set 9Other

SAFLS)" <AVillafan

From: SAFLS)" <AVillafan usa.do. ov> To: ' (USAFLS)" < "Ferrer, Wifredo A. (USAFLS)" S)" <WJacobus®usa.doj.gov>, "Atkinson, Karen (USAFLS)" <ICAtkinson®usa.doj.gov> Cc: ' (USAFLS)" • Subject: FW: follow up today's filing -- re Victims' Rights Suit Date: Thu, 28 Oct 2010 01:16:38 +0000 Importance: Normal Attachments: DE41_20101027_Resp_to_Order_to_Show_Cause.pdf Good evening, everyone. I have attached what was filed in the District Court, and below is Judge Cassell's latest correspondence. I will let you digest and we can talk tomorrow. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 From: Paul Castel! [mallto:i 7, 2010 8:39 PM Subject: follow up today's filing 1. Via PACER, you will have seen the pleading that we have filed today. We are saddened that the U.S. Attorney's Office has not seen fit to make any concession to us, while at the same time asking us to delay filing our pleadings. Nonetheless, as a show of good faith,

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DOJ Data Set 9
Reference
EFTA 00206877
Pages
2
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3
Integrity

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From: SAFLS)" <AVillafan usa.do. ov> To: ' (USAFLS)" < "Ferrer, Wifredo A. (USAFLS)" S)" <WJacobus®usa.doj.gov>, "Atkinson, Karen (USAFLS)" <ICAtkinson®usa.doj.gov> Cc: ' (USAFLS)" • Subject: FW: follow up today's filing -- re Victims' Rights Suit Date: Thu, 28 Oct 2010 01:16:38 +0000 Importance: Normal Attachments: DE41_20101027_Resp_to_Order_to_Show_Cause.pdf Good evening, everyone. I have attached what was filed in the District Court, and below is Judge Cassell's latest correspondence. I will let you digest and we can talk tomorrow. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 From: Paul Castel! [mallto:i 7, 2010 8:39 PM Subject: follow up today's filing 1. Via PACER, you will have seen the pleading that we have filed today. We are saddened that the U.S. Attorney's Office has not seen fit to make any concession to us, while at the same time asking us to delay filing our pleadings. Nonetheless, as a show of good faith,

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From: SAFLS)" <AVillafan usa.do. ov> To: ' (USAFLS)" < "Ferrer, Wifredo A. (USAFLS)" S)" <WJacobus®usa.doj.gov>, "Atkinson, Karen (USAFLS)" <ICAtkinson®usa.doj.gov> Cc: ' (USAFLS)" • Subject: FW: follow up today's filing -- re Victims' Rights Suit Date: Thu, 28 Oct 2010 01:16:38 +0000 Importance: Normal Attachments: DE41_20101027_Resp_to_Order_to_Show_Cause.pdf Good evening, everyone. I have attached what was filed in the District Court, and below is Judge Cassell's latest correspondence. I will let you digest and we can talk tomorrow. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 From: Paul Castel! [mallto:i 7, 2010 8:39 PM Subject: follow up today's filing 1. Via PACER, you will have seen the pleading that we have filed today. We are saddened that the U.S. Attorney's Office has not seen fit to make any concession to us, while at the same time asking us to delay filing our pleadings. Nonetheless, as a show of good faith, we are delaying filing our motion so that we can continue discussions with your Office. 2. As noted in our pleading — and as this e-mail will serve to confirm —while we are willing to continue discussions with you, we respectfully request that you immediately begin preparing your response to our motion so that if it becomes necessary for us to file it, your response can be filed quickly as well without any delay. 3. You have previously promised to review our statement of facts and tell us which facts are being disputed — and to work with us to narrow the range of disputes. As you know, we would like to work with you quickly on that effort. Could you get back to us by Friday, October 29, 2010, on that point and then have a telephone conference call with us on that date to work out the disputed facts? 4. This e-mail will also serve to confirm our request, previously raised in our October 22, 2010, letter to you, for access to correspondence relevant to Jane Doe #1 and Jane Doe #2's claims. We have not heard back from you on whether you intend to give us access to this information and, if not, what is the basis for withholding that information. 5. Our October 22, 2010, letter also indicated our surprise at the suggestion that we need to file some sort of civil complaint to resolve this matter. We explained why such an approach was, to our knowledge, not standard procedure in CVRA cases. Could you please advise as to what mechanism you think we need to deploy to bring this matter to a conclusion. 6. Your e-mail today takes the position that this CVRA case is a "civil" case and therefore that CVRA rights (like the right to confer) need not be provided to Jane Doe #1 and Jane Doe #2. We don't understand this position. In 2007-08, Jane Doe #1 and Jane Doe #2 were advised by your office that they had CVRA rights in the Epstein case. Our CVRA EFTA00206877 motion is clearly filed in connection with that case. Do you think we need to re-docket our case so that it links directly to the CVRA case that you were providing notices about. If so, could you let us know what you think is the proper procedure for making that linkage. 7. While we would like to resolve these particular items with you quickly, in addition we would like to meet with the U.S. Attorney to discuss how to best move forward on this case on the morning of November 8, 2010 - if that is a convenient date for the U.S. Attorney. Thanks for your prompt attention to these issues. We look forward to working with you and others in the office to try and resolve this matter in a way that is fair to all concerned. Sincerely, Paul Cassell Co-Counsel for Jane Doe #1 and Jane Doe tt2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Quinney College of Law at the University of Utah 332 South 1400 East, Room 101 Salt Lake City, UT 84112-0730 http://www.law.utah.eduiprofiles/default.asp?RersoMD=57&name=Cassell Paul 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. EFTA00206878

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Related Documents (6)

DOJ Data Set 9OtherUnknown

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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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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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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DOJ Data Set 9OtherUnknown

STATEMENT BY ALAN DERSHOWITZ

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DOJ Data Set 9OtherUnknown

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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DOJ Data Set 9OtherUnknown

From: '

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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