u jec :

Date

Unknown

Source

DOJ Data Set 9

Reference

EFTA 00210120

Pages

Persons

Integrity

Summary

Persons Referenced (1)

Paul Cassell

Extracted Text (OCR)

EFTA Disclosure

Text extracted via OCR from the original document. May contain errors from the scanning process.

u jec : : motion to compe -- correct proce tires . Date: Sat, 18 Jul 2015 00:01:51 +0000 Importance: Normal Paul, Thanks for sending this to us. We agree this is the correct procedural format for placing the issue before the Court, on whether the government is obligated to search for, and produce, information responsive to the supplemental requests for production we objected to, as well as responding to the supplemental requests for admission, which we objected to. From: Paul Cassell [mailto:cassellp©law.utah.edu] Sent: Wednesday, July 15, 2015 5:43 PM . : motion t0 compel -- correct Droceaures . Thanks for getting back to us earlier with with information about Dershowitz. We really appreciate it. As we have discussed, Brad and I think we're entitled to your Dershowitz information -- of course, you disagree. The next step now is how to present this issue to Judge Marra. In the interest of avoiding unnecessary disputes, Brad and I wanted to share with you a DRAFT motion to compel. It is a draft -- and is still lacking some of the substantive arguments about why we think that Dershowitz information is relevant - - Brad and I are still working on that section of the motion. But we wanted to share the current draft with you now to make sure that we are making accurate representations about how you think this is the right vehicle to present these questions to the court. See pp. 1-2 and pp. 3-4 of attached draft. Brad and I are hopeful that we will finish the draft in the next few days. We then plan to circulate to you, as well as to Epstein's and Dershowitz's lawyers to get their approval (or objection) to this procedure. But before going to them, we wanted to work together with you, so that the two parties to the case could have an agreed procedure -- before turning to prospective intervenors. So -- bottom line -- understanding fully that you are not agreeing with any of our SUBSTANTIVE claims in this motion, are we moving forward PROCEDURALLY in the way the Government thinks is appropriate? If not, please let us know another way to proceed, so we can avoid objections. Thanks again for your help. Paul and Brad for the victims EFTA00210120 for the use of the addressee. eceived this message in admitted to the Utah State EFTA00210121

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Related Documents (6)

DOJ Data Set 9OtherUnknown

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

DOJ Data Set 9OtherUnknown

Subject: RE: Are you free to call Paul Cassell now?

From: To: Subject: RE: Are you free to call Paul Cassell now? Date: Mon, 14 Dec 2009 17:58:02 +0000 Importance: Normal I did. She was driving and her phone was cutting out. I just sent her an emailing explaining how this all intersects and told her to hold off about making anymore contact wit o as to try to keep criminal vs. civil cases as separate as possible. From: Villafana, Ann Marie C. (USAFLS) (Ann.Marie.C.Villafana©usdoj.gov] Sent: Monday, December 14, 2009 12:35 PM To: Pryor, Christina Jo Subject: RE: Are you free to call Paul Cassell now? Did you tell her that is not a victim? Eshould only be classified as a witness. Assistant U.S. Attorne 500 E. Broward Blvd, Ft Lauderdale, FL 33394 From: Pryor, Christina Jo (FBI) Sent: Monday, December 14, 2009 11:53 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Are you free to call Paul Cassell now? I just talked with She said had identified=as a victim and per procedure, she made an initial contact introduci

House OversightUnknown

Alleged criminal extortion plot discussed during Alan Dershowitz's 2015 Broward County deposition

Alleged criminal extortion plot discussed during Alan Dershowitz's 2015 Broward County deposition The passage references a claim that Alan Dershowitz disclosed a criminal extortion scheme involving unnamed clients during a deposition, and mentions related defamation lawsuits. While the details are vague and unverified, the involvement of a high‑profile attorney and a federal courtroom provides a concrete lead (date, location, parties) that could be pursued. The claim is moderately controversial and potentially sensitive, but it lacks clear novelty and specific financial details, limiting its score. Key insights: Dershowitz allegedly told lawyers Brad Edwards and Paul Cassell that "your clients were involved" in a criminal extortion plot.; The statement was made on October 15, 2015, during a deposition in Broward County, Florida.; Bradley and Cassell had sued Dershowitz for defamation, and Dershowitz had filed a countersuit.

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

DOJ Data Set 9OtherUnknown