From: Paul Cassell <I
Summary
From: Paul Cassell <I Cc: Brad Edwards <1 Subject: RE: motion for additional pages + Government position on three additional motions Date: Wed, 04 Feb 2015 15:24:50 +0000 Importance: Normal Hi 1. We are planning on filing a motion for additional pages for our reply in support of 3D3 and JD4's motion to intervene. We are requesting that you not oppose a motion for our reply not to exceed 18 pages. The additional pages are required because we have to discuss some complicated legal issues relevant to the statute of limitations issue you presented, including the "beyond the seas" tolling provision as well as the interaction of the 2401(a) and the applicable criminal statutes of limitations. We also have to discuss the issue of whether the CVRA contains a statute of limitations. Please advise if you will agree to this motion. 2. As you know, we sent a letter to Mr. Ferrer (with copy to you) regarding three motions that we are preparing to file. We were hoping to receive an answ
Persons Referenced (3)
Tags
Search 264K+ documents with AI-powered analysis
Extracted Text (OCR)
EFTA DisclosureRelated Documents (6)
Jeffrey Epstein Child Sex Trafficking Investigation – FBI Records, Deleted Pages, Non‑Prosecution Deal, High‑Profile Connections
The compiled documents reveal a dense web of FBI case files, internal forms, and communications that reference Jeffrey Epstein’s illegal sexual activities with minors, a secret non‑prosecution agreeme FBI case number 31E‑MM‑108062 repeatedly references ‘Child Locate’ entries and deleted pages (b6, b7 Multiple internal FD‑515 forms list Jeffrey Epstein as a subject (named explicitly on 09/30/2008 e
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CI V-Marra/Matthewman JANE DOE # I and JANE DOE #2, Petitioners, I UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "government") hereby responds to Jane Doe #1 and Jane Doe #2's First Request for Admissions to the Government Regarding Questions Relevant to Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for Admissions"), and states as follows:' I. The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses. Except as otherwise admitted above, the government denies Request No. I. The government's res
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
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
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
Attorney Bradley Edwards alleges Jeffrey Epstein's non‑prosecution agreement, 5th Amendment tactics, and a unique George Rush tape as key evidence ...
The affidavit details a non‑prosecution agreement that shielded Epstein from federal charges, claims that Epstein repeatedly invoked the Fifth Amendment to block discovery, and describes a purportedly Epstein secured a federal non‑prosecution agreement that barred criminal charges for ~30 victims in All co‑defendants and Epstein invoked the Fifth Amendment, leaving plaintiffs with no substantive
Forum Discussions
This document was digitized, indexed, and cross-referenced with 1,400+ persons in the Epstein files. 100% free, ad-free, and independent.