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To: "'Paul Cassell"

From: To: "'Paul Cassell" Cc: Subject: RE: Tracking down materials Date: Wed, 28 Sep 2016 15:33:03 +0000 Importance: Normal "'Brad Edwards"' <brad@pathtojustice.com> Hi Paul — I hope that are well. I have been out of the office for a bit, but have been working on your requests. 1.1as been in contact with the FBI and they are checking on whether there are responsive emails and how we go about accessing any, should they exist. I know that we had some conversation about narrowing the requests, but we believe that you need to try to narrow them in writing so that we can determine whether we need to apply to the Court to quash or limit the requests. As written, and even following the discussion, they are so broad and vague that we do not feel that we can respond. Some seem to call for a search of every government computer file, which would be impossible. Do you want to try to be more specific and, in the meantime we will continue our efforts with the FBI and with items tha

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DOJ Data Set 9
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EFTA 00211196
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From: To: "'Paul Cassell" Cc: Subject: RE: Tracking down materials Date: Wed, 28 Sep 2016 15:33:03 +0000 Importance: Normal "'Brad Edwards"' <brad@pathtojustice.com> Hi Paul — I hope that are well. I have been out of the office for a bit, but have been working on your requests. 1.1as been in contact with the FBI and they are checking on whether there are responsive emails and how we go about accessing any, should they exist. I know that we had some conversation about narrowing the requests, but we believe that you need to try to narrow them in writing so that we can determine whether we need to apply to the Court to quash or limit the requests. As written, and even following the discussion, they are so broad and vague that we do not feel that we can respond. Some seem to call for a search of every government computer file, which would be impossible. Do you want to try to be more specific and, in the meantime we will continue our efforts with the FBI and with items tha

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From: To: "'Paul Cassell" Cc: Subject: RE: Tracking down materials Date: Wed, 28 Sep 2016 15:33:03 +0000 Importance: Normal "'Brad Edwards"' <brad@pathtojustice.com> Hi Paul — I hope that are well. I have been out of the office for a bit, but have been working on your requests. 1.1as been in contact with the FBI and they are checking on whether there are responsive emails and how we go about accessing any, should they exist. I know that we had some conversation about narrowing the requests, but we believe that you need to try to narrow them in writing so that we can determine whether we need to apply to the Court to quash or limit the requests. As written, and even following the discussion, they are so broad and vague that we do not feel that we can respond. Some seem to call for a search of every government computer file, which would be impossible. Do you want to try to be more specific and, in the meantime we will continue our efforts with the FBI and with items that are fairly specific (e.g., you specifically refer to which is something we have been and can continue to look into)? The certificates of service specify different dates, but my records show that they were served on August 31g, is that consistent with your records? Thanks so much. Assistant U.S. Attorney Southern District of Florida From: Paul Cassell Sent: Tuesday, September 27, 2016 3:18 PM To: 'Brad Edwards' <brad@pathtojustice.com> Cc: Subject: RE: Tracking down materials Just wanted to touch base and see how things are coming collecting the information that we talked about on the phone on September 2, if I recall correctly? As mentioned, I hopefully gave you precise enough information that finding the materials would not have been time consuming on your end. Just wanted to see if you had any more questions about that. Brad and I can assist if needed. Paul Cassell for Jane Doe 1 and 2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law University Distinguished Professor of Law S J Ouinnev College of Law at the University of Utah EFTA00211196 Lura-lucil I IP.L. WI] Illeb>cte • caul% mei eityien WIllItluntial. 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. From: Paul Cassell Sent: Wednesday, Au ust 31, 2016 3:28 PM To: Brad Edwards Cc Subject: RE: Conf call re scheduling and discovery? I free at that time on Friday — 3 PM Florida time, 1 PM Utah time. Glad to chat. Please call my cell, a Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law University Distinguished Professor of Law I Chlinnev rnllecie nf I AW at the I Inivercitv nf !Nab PC 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. From: Brad Edwards Sent: Wednesday, August 31, 2016 3:26 PM To: Cc: Paul Cassel Subject: Re: Conf call re scheduling and discovery? I have a deposition Friday afternoon but don't need to be on the call if Paul is free. Sent from my iPhone On Aug 31, 2016, at 5:15 PM, wrote: Hi Brad and Paul — Can we do a conference call to talk about the schedule? I am totally booked tomorrow and Dexter has a mediation on Friday morning, so I was hoping we could chat at 3:00 on Friday. Please let me know if that works and I will set up a conference line. Thanks. EFTA00211197 Assistant U.S. Attorney Southern District of Florida EFTA00211198

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Related Documents (6)

DOJ Data Set 9OtherUnknown

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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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

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

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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