To: Paul Cassell

Date

Unknown

Source

DOJ Data Set 9

Reference

EFTA 00204876

Pages

Persons

Integrity

Summary

Persons Referenced (2)

Bradley Edwards Paul Cassell

Extracted Text (OCR)

EFTA Disclosure

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

From: To: Paul Cassell Cc: Subject: Government Position Date: Fri, 03 Feb 2012 16:10:25 +0000 Importance: Normal Brad Edwards Paul and Brad, I am responding to your e-mail on February 1, 2012 regarding our filing the entire reply under seal. We respectfully disagree that such a filing was inappropriate, a violation of DOJ policy, and/or a violation of First Amendment principles. Our filing the entire reply under seal is based upon the November 7, 2011 Order from Judge Middlebrooks, permitting the government to make limited disclosure of Grand Jury matter. Judge Middlebrooks permitted disclosure under three conditions, including that "the disclosure of the aforementioned grand jury information shall be limited to filings made under seal in Case No. 08-80736-CIV-MARRA." We understand your desire to share the government's filing with your colleagues in the victims' ri hts communit . However, the November 7, 2011 Order also limits service of filings to counsel for petitioners Distributing these government's filings, which were filed under seal, would not be p 7, 2011 order. While we appreciate all the courtesies both of you have extended to us over the course of this litigation, and particularly over the last two months, we would oppose a motion that the government file a redacted pleading in the open court file. I think we have a fundamental disagreement over the what constitutes protected Grand Jury material, and how readily such protected material can be segregated from non-protected information. As far as the information at page 32 n.20, of the government's reply, the government would need to obtain additional authorization from the Court under Fed.R.Cr.P. 6(e) to disclose the information supporting jurisdiction and venue in the Southern District of New York and the District of New Jersey. When you refer to "unsealing of all information," if you mean that such information would be publicly disclosed, we would oppose such a motion. If authorization were obtained under Rule 6(e) for additional disclosures as to venue in those two jurisdictions, we would expect that such material would only be disclosed under the same conditions in the November 7, 2011 Order. As far as your proposed motion for the court to deny the motion to dismiss without requiring additional pleadings from the victims, we don't see how such a motion is necessary. Since the motion is now fully briefed, the court can grant or deny the motion to dismiss without requiring additional pleadings from any party, unless the court believes it needs more briefing. Normally, sur-replies are not permitted unless the reply has gone beyond responding to the issues raised in the response. We don't believe our reply brought forward new issues not raised in our motion to dismiss. I'll be here all day. Thanks. EFTA00204876

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Dershowitz’s evasive discovery responses in Edwards v. Dershowitz case

Dershowitz’s evasive discovery responses in Edwards v. Dershowitz case The passage reveals a pattern of non‑compliance and vague objections by a high‑profile attorney in a civil suit, suggesting possible concealment of documents. While it provides specific dates and procedural details useful for follow‑up, it lacks concrete allegations of wrongdoing, financial flows, or involvement of powerful political actors, limiting its impact. Key insights: Discovery requests for “absolute proof” were served well before February 2015.; Dershowitz’s counsel promised production by Feb 23, 2015 but delivered no documents.; Responses were limited to generic objections and promises of “non‑privileged” documents.

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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Dershowitz seeks to seal Giuffre affidavit in Edwards‑Cassell defamation case, claims media attacks are fabricated

Dershowitz seeks to seal Giuffre affidavit in Edwards‑Cassell defamation case, claims media attacks are fabricated The passage hints at a possible concealment of evidence in a high‑profile defamation dispute involving Alan Dershowitz, a prominent attorney, and references the infamous Giuffre allegations. While it names well‑known legal figures, it provides no concrete financial transactions, dates, or new factual revelations beyond already public claims, limiting its investigative utility. However, the suggestion that a court record may be sealed to hide potentially damaging testimony offers a moderate lead for further document‑review and freedom‑of‑information requests. Key insights: Dershowitz requests the court to declare portions of Ms. Giuffre’s affidavit confidential.; He publicly denies the allegations on BBC Radio 4, framing them as a coordinated false‑story campaign.; Dershowitz threatens perjury prosecution against accusers and seeks disbarment of opposing counsel.

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