EFTA00209597.pdf

From: Paul Cassell <MIII > To: IS s I. (USAFLS)" Cc: Edwardr, (USAFLS)" Subject: RE: Lack of jurisdiction in the Eleventh Circuit Date: Fri, 28 Jun 2013 16:09:35 +0000 Importance: Normal Attachments: victim-opposition-mts.pdf Hi ands 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: Fax: Email: http://www.law.utah.edu/profiles/default.asp?PersonID=57&name assell,Paul 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. Oita sa From: s I. (USAFLS) [mailto Sent: Friday, June 28, 2013 8:03 AM To: Paul Cassell Cc: Edwards Brad; M, s (USAFLS) Subject: Re: Extension of time re redaction Hi Paul: Thank you for being so accommodating. I know you worked up at Main, so I think you know that all appellate decisions are made by appellate attorneys. is handling getting an answer and will get back to you as soon as he can. Have a wonderful weekend. I am sure we will talk soon. Regards, EFTA00209597 A. Villafafia Assistant US Attorney Sent from my iPhone On Jun 28, 2013, at 9:38 AM, "Paul Cassell" wrote: > Hi=, > We're happy to work with you on this, so we have no objection. > But we were wondering when you would get back to us on our question (emailed to you yesterday morning) regarding the Government's position on Epstein's (frankly unprecedented) attempt to take an interlocutory appeal in the middle of this case. Is the Government going to oppose that effort? We would be very surprised if the Government wanted to set a precedent allowing suspected criminals to take interlocutory appeals in the middle of cases involving criminal proceedings. We'd like to know quickly, because we are filing very soon in opposition to the motion to stay. > Paul and Brad 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 S. 1400 E. , Room 101 > Salt Lake Cit , UT 84112-0730 (phone) fax > You can access my publications on http://ssrn.corn/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. > From: SAFLS) > Sent: Friday, June 28, 2013 6:41 AM > To: Paul Cassell; Edwards Brad > Cc: (USAFLS) M, > Subject: Extension of time re redaction > Dear Paul and Brad: > Good morning. I am writing to ask if you have any objection to a motion for a short extension of time to comply with Judge Marra's order requiring us to file unredacted pleadings. Some of those have Judge Middlebrooks' sealed order attached and I need to file something with Judge Middlebrooks to avoid getting caught in the crosshairs. I am pretty sure that he is in town, so 5 days should suffice. If it will be longer than that, I will send a follow-up email. > Thank you so much. > A. Villafafia EFTA00209598 > Assistant US Attorney > Sent from my iPhone EFTA00209599