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From: Paul Cassell 4 -

From: Paul Cassell 4 - To: ' (USAFLS)( Cc: Brad Edwards cj Subject: RE: intimidation/threat to. yesterday -- requesting help to reach an FBI agent - sweep of home Date: Sun, 18 Jan 2015 19:00:28 +0000 Importance: Normal Hi US Attorney's Office team, Trying to coordinate the local law enforcement side of this with the FBI. of the Florence (Colorado) police can be reached at . He has been in touch with this morning -- there is discussion about whether the FBI could do a sweep of home for a bug, as the local police agency does not have the proper equipment. Is there some way to have the FBI agents who worked with contact to make appropriate arrangements on tall this? Brad and I are sure that you will see the importance of the situation and extend help -- please confirm. Paul Cassell (and Brad Edwards) for El Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. •uinne Colle e of Law at the University of Utah You can access my publications on h

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DOJ Data Set 9
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EFTA 00211008
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From: Paul Cassell 4 - To: ' (USAFLS)( Cc: Brad Edwards cj Subject: RE: intimidation/threat to. yesterday -- requesting help to reach an FBI agent - sweep of home Date: Sun, 18 Jan 2015 19:00:28 +0000 Importance: Normal Hi US Attorney's Office team, Trying to coordinate the local law enforcement side of this with the FBI. of the Florence (Colorado) police can be reached at . He has been in touch with this morning -- there is discussion about whether the FBI could do a sweep of home for a bug, as the local police agency does not have the proper equipment. Is there some way to have the FBI agents who worked with contact to make appropriate arrangements on tall this? Brad and I are sure that you will see the importance of the situation and extend help -- please confirm. Paul Cassell (and Brad Edwards) for El Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. •uinne Colle e of Law at the University of Utah You can access my publications on h

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From: Paul Cassell 4 - To: ' (USAFLS)( Cc: Brad Edwards cj Subject: RE: intimidation/threat to. yesterday -- requesting help to reach an FBI agent - sweep of home Date: Sun, 18 Jan 2015 19:00:28 +0000 Importance: Normal Hi US Attorney's Office team, Trying to coordinate the local law enforcement side of this with the FBI. of the Florence (Colorado) police can be reached at . He has been in touch with this morning -- there is discussion about whether the FBI could do a sweep of home for a bug, as the local police agency does not have the proper equipment. Is there some way to have the FBI agents who worked with contact to make appropriate arrangements on tall this? Brad and I are sure that you will see the importance of the situation and extend help -- please confirm. Paul Cassell (and Brad Edwards) for El Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. •uinne Colle e of Law at the University of Utah You can access my publications on http://ssrn.com/author=30160 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 in error, please immediately notify the sender by reply electronic mall and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the bars of other states. Thank you. From: Paul Cassell Sent: Sunda , Janua 18, 2015 10:01 AM To: (USAFLS) ( ); (USAFLS); Cc: Brad Edwards Subject: intimidation/threat to E yesterday -- requesting help to reach an FBI agent Dear US Attorney's Office team, I am writing to see if you can put me in touch with one of your FBI agents. appears to be receiving threats. Here's the situation. IMI now resides in Penrose, Colorado. Yesterday she went to the WalMart there and was followed by a dozen members of the British media. She had to call WalMart security just to get out of the store. When she, her husband, and kids returned to their home, they found the backdoor to their home had been left open. They had been taking high securi precautions, so that seemed very unusual. Brad and I believe that this may be Epstein (or his associates) signaling that ■ should not talk. I called the FBI in Colorado this morning, which bounced me to a national call center -- I tried to pass along information to them about the possible threat to IN (who, as you know, as cooperated with the FBI). The call center did not appear to take the threat seriously, said that the FBI would not be a first responder, and told me to call local law enforcement. EFTA00211008 I then called the Penrose/Florence Police Department. They appear to be taking the matter seriously and are in the process of looking into the possible burglary yesterday afternoon. I am writing to see if you can provide me with contact information for one of the FBI agents who has worked with in the past -- obviously a number of the people who would have a reason to make disappear are known to the FBI, and we haven't disclosed them to the Florence PD (I just sent our pleading, which mentions the five or so names that are in controversy now.) I would like to alert the FBI to the situation so that they can help provide assistance to U, either directly or perhaps working through local law enforcement. If it would be better for the agent to just call me directly, my cell phone is Thank you for any assistance you can extend rapidly on this important matter. Paul Cassell (and Brad Edwards) for Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah You can access my publications on http://ssrn.com/author=30160 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 in error, please immediately notify the sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the bars of other states. Thank you. EFTA00211009

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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

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

Filing # 35429605 E-Filed 12/11/2015 10:08:04 AM

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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

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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

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