EFTA00207934.pdf

Cc: Brad Edwards <bedwards@pathtojustice.com> Subject: RE: extra pages Date: Sun, 04 Dec 2011 19:07:17 +0000 Importance: Normal Thanks for asking -- yes everything went smoothly. Paul 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, 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. C. :fa , is Subject: RE: extra pages No objection to the extra pages. I hope that all went well on Friday. ----Original Message-- From: Paul Cassell [mailto:cassellp©law.utah.edu] Sent: Sunday December 04 2011 1:55 PM Cc: Brad Edwards Subject: RE: extra pages Sorry I had to leave the call early Friday. Meant to check with you on this then. I am working with Brad to finalize our pleadings to be filed on Monday in response to the motion to dismiss. We are filing an unsealed pleading (that does not discuss grand jury material) as well as a sealed pleading (that discusses only the grand jury material and related issues). The unseal pleading is 24 pages long and the sealed pleading is 7 pages long. We also have a response to the motion to stay which is well under the 20 page limit. Any objection to a motion for the extra pages (4 + 7, although Pm not sure whether we count the 7) to respond to your motion to dismiss? EFTA00207934 Thanks for your help on getting back to us. PC 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, 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. Cc: Brad Edwards Subject: RE: Conference call 11:15 AM Florida time - Friday Paul, We will take care of the arrangements for tomorrow at 11:15 a.m. Thanks. From: Paul Cassell mailto:cassellSlaw.utah.edu] Sent: Thursday, December 01 2011 4:59 PM Subject: RE: Conference call 11:15 AM Florida time - Friday Hi all, Does 11:15 AM Florida time on Friday work? If so, please call my cell phone as well as Brad - Ed/Dexter can y'all initiate the conference call or set up a call in number? Looking forward to chatting. PC Paul G. Cassell— Ronald N. Boyce Presidential Professor of Criminal Law 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. Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? EFTA00207935 Hi everyone - Sony, I am having a very busy duty week. Tomorrow I have court at 9:00 probably until 11:00 and then again from 3:00 until 5:00. I have a debriefing at 1:00, but I should be able to step out after 1:30. So, 11:15 or 1:30 are best for me, but your schedules take priority. Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? Unfortunately, that doesn't work for us today. Can we set up a time for tomorrow? -----Original Message-- From: Paul Cassell [mailto:cassella@law.utah.edu]Vmailtolmailto:cassellp@law.utah.edui> Sent: Thursday, December 01, 2011 2:22 PM Cc: Brad Edwards Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? Thanks for the call. Sony I was on the other line. Can we set up a time certain? That way Brad can participate. He is in a depo until 4:30, but should be free at 5 PM your time today (Thursday). Does that work? EFTA00207936 Looking forward to chatting. PC 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, 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. -----Original Message-- From: Paul Cassell Sent: Thursday, December 01, 2011 11:25 AM We will shortly be filing a motion to compel Government responses to our discovery requests — discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay. But if the Government's position is rejected on those motions, then the next issue is what discovery can we expect to receive from the Government. If the motions are denied, will the Government voluntarily produce anything to us? Will the government at least agree to produce the following: EFTA00207937 (I) The Government's initial disclosures pursuant to Fed. R. Civ. P. 26; (2) Answers to all of the victims' requests for admission; (3) All documents, correspondence, and other information that the Government distributed to persons or entities outside of the federal Government or received from persons or entities outside of the federal government; and (4) All documents, correspondence, and other information covered by the victims' discovery request that is not subject to a claim of privilege. And, for all other information withheld, will the Government agree to produce a document-bydocument privilege log, as required by the local rules? Thanks for your help on these questions and Brad and I have. Sincerely, Paul Cassell Co-Counsel for Jane Doe #1 and Jane Doe N2 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. EFTA00207938