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efta-efta00206679DOJ Data Set 9Other

From: Paul Cassell <

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DOJ Data Set 9
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EFTA 00206679
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From: Paul Cassell < To: Paul Cassell < >, (USAFLS)" < Cc: Brad Edwards ' Subject: RE: Proposed Pleading to File - fixed a couple of sentences Date: Wed, 27 Oct 2010 20:10:21 +0000 Importance: Normal Attachments: response-order-show-cause-usattyrevision2.docx (USAFLS)" I noticed that I missed a couple of sentences in the pleading I sent to you that made reference to the simultaneously filed declaration of Brad Edwards. This revision fixes those couple of sentences, making reference only to a soon-to-be filed declaration. Paul Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah Salt Lake City, UT 84112-0730 tip: %WAY. aw.ut pro t es/default.asp?PersonID=578zname=Cassell Paul 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 i

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From: Paul Cassell < To: Paul Cassell < >, (USAFLS)" < Cc: Brad Edwards ' Subject: RE: Proposed Pleading to File - fixed a couple of sentences Date: Wed, 27 Oct 2010 20:10:21 +0000 Importance: Normal Attachments: response-order-show-cause-usattyrevision2.docx (USAFLS)" I noticed that I missed a couple of sentences in the pleading I sent to you that made reference to the simultaneously filed declaration of Brad Edwards. This revision fixes those couple of sentences, making reference only to a soon-to-be filed declaration. Paul Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah Salt Lake City, UT 84112-0730 tip: %WAY. aw.ut pro t es/default.asp?PersonID=578zname=Cassell Paul 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. From: Paul Cassell Sent: Wednesday, October 27, 2010 1:50 PM Subject: RE: Proposed-Pleading to File THE FOLLOWING COMMUNICATION IS A SETTLEMENT OFFER WITHIN THE MEANING OF FEDERAL RULE OF EVIDENCE 408 Attached is proposed pleading that we would file, reflecting your request that we delay and reflecting your stipulation that the passage of time to this point has not prejudiced the U.S. Attorney's Office. I want to continue to remind your office of its obligation to use its "best efforts" to protect the rights of crime victims. 19 USC 3771(c) (I). I trust that as you review our proposed pleading you will bear that requirement in mind. I can be reached on my cell at As you know, we have to file today and are prepared to do so if we can't work something out. At the same time, we would like to work cooperatively with your office to bring Epstein to justice — our revised pleadings are a step in that direction, while hopefully responding to the concerns that your Office has raised. Paul Cassell Counsel for Jane Doe #1 and Jane Doe #2 EFTA00206679 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah Salt Lake City, UT 84112-0730 httplAvww.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell Paul 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. Sent: Monday, October 25, 2010 10:16 AM To: Paul Cassell Subject: Out of Office AutoReply: Conferring on Statement of Facts Before Wednesday's Filing I will be on government travel from October 25.26, 2010. If you need to reach me, please call me at Thanks. EFTA00206680

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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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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

From: Paul Cassell To: Cc: Brad Edwards Subject: ere o "e tan on t e ropose tatement of Facts? Date: Mon, 08 Nov 2010 21:24:26 +0000 Importance: Normal Hi Brad and I both agree that we need to get the facts resolved first, then discuss where we go from there. At the same time, we want to get this moving along. Can we set a specific time line for getting the facts resolved — is there a time that works for you and in the near future to have a conference call? Then is there a specific time shortly after Thanksgiving that would workyou're your U.S. Attorney? Paul Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law http://www.law.utah.edu/profiles/default.asp?PersonID=S7&name=Cassell Paul 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

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