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efta-efta00211880DOJ Data Set 9Other

Subject: FW: Draft Protective Order

From: To:' Subject: FW: Draft Protective Order Date: Fri, 15 Aug 2008 16:10:04 +0000 Importance: Normal Attachments: Protective Order.Final.doc Hey Dexter — I am going to leave this to you, if that is alright. I know it is difficult when too many cooks get involved. Assistant U.S. Attorney 5OO S. Australian Ave, Suite 400 West Palm Beach, FL 33401 From: Brad Edwards Sent: Frida Au ust 15 2008 11:59 AM To: Subject: RE: Draft Protective Order This is my proposed Order. I think it comports with the Judge's order from yesterday and I think it is slightly more thorough. It is very similar to your Motion. If you are more satisfied with your wording or layout for the motion, then please incorporate the additional points made in my proposed order. My only real problem with your proposed Order is paragraph C. This just further delays us from getting the agreement, and I do not believe the Judge placed this burden on us. I think, as I wrote in my proposed order, that it is my

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DOJ Data Set 9
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EFTA 00211880
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From: To:' Subject: FW: Draft Protective Order Date: Fri, 15 Aug 2008 16:10:04 +0000 Importance: Normal Attachments: Protective Order.Final.doc Hey Dexter — I am going to leave this to you, if that is alright. I know it is difficult when too many cooks get involved. Assistant U.S. Attorney 5OO S. Australian Ave, Suite 400 West Palm Beach, FL 33401 From: Brad Edwards Sent: Frida Au ust 15 2008 11:59 AM To: Subject: RE: Draft Protective Order This is my proposed Order. I think it comports with the Judge's order from yesterday and I think it is slightly more thorough. It is very similar to your Motion. If you are more satisfied with your wording or layout for the motion, then please incorporate the additional points made in my proposed order. My only real problem with your proposed Order is paragraph C. This just further delays us from getting the agreement, and I do not believe the Judge placed this burden on us. I think, as I wrote in my proposed order, that it is my

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From: To: ' Subject: FW: Draft Protective Order Date: Fri, 15 Aug 2008 16:10:04 +0000 Importance: Normal Attachments: Protective Order.Final.doc Hey Dexter — I am going to leave this to you, if that is alright. I know it is difficult when too many cooks get involved. Assistant U.S. Attorney 5OO S. Australian Ave, Suite 400 West Palm Beach, FL 33401 From: Brad Edwards Sent: Frida Au ust 15 2008 11:59 AM To: Subject: RE: Draft Protective Order This is my proposed Order. I think it comports with the Judge's order from yesterday and I think it is slightly more thorough. It is very similar to your Motion. If you are more satisfied with your wording or layout for the motion, then please incorporate the additional points made in my proposed order. My only real problem with your proposed Order is paragraph C. This just further delays us from getting the agreement, and I do not believe the Judge placed this burden on us. I think, as I wrote in my proposed order, that it is my duty to instruct my clients on the protective order and its function and to otherwise ensure that it is not violated by my clients. Getting my clients to "acknowledge receipt of the order and agree to its terms" could take awhile and cause unnecessary delay. I plan to talk to my clients about "the agreement' and at the same time instruct them as to the rules outlined in the protective order. That is all the Judge indicated as needed to be done. From: Sent: Frida Au ust 15, 2008 11:41 AM To: (USAFLS) Subject: Draft Protective Order Brad, Attached please find a draft protective order regarding the disclosure of the non-prosecution agreement to you and Jane Does 1 and 2. Please let us know if there are any changes you wish to make. Thanks. <<Protective Order.doc» EFTA00211880

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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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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I UNITED STATES DECLARATION OF BRADLEY J. EDWARDS, ESQ. I. I, Bradley J. Edwards, Esq., do hereby declare that I am a member in good standing of the Bar of the State of Florida. Along with co-counsel, I have represented Jane Doe #1 and Jane Doe #2 in civil suits against Jeffrey Epstein for sexually abusing them. I have also represented other girls who were sexually abused by Epstein. As a result of that representation, I have become familiar with many aspects of the criminal investigation against Epstein and have reviewed discovery and correspondence connected with the criminal investigation. I have also spoken to Jane Doe #1 and Jane Doe #2 at length about the criminal investigation and their involvement in it, as well enforcement (or lack their of) of their rights as crime victims in the investigation. I also represent Jane Doe #1 and Jane Doe #2 in the pen

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From: Brad Edwards To: Cc: Paul Cassell Subject: Re: Rescheduling Settlement Conference - bad date Date: Sat, 25 Jun 2016 20:39:34 +0000 Importance: Normal Inline-Images: image001.png; image002.png I will forward everything to Paul. is calling me Tuesday. I will use that time to relay everything to her and see where we are then. Sent from my iPhone On Jun 25, 2016, at 4:23 PM, wrote: Hi Paul — Thank you for your email. July 5th is bad for us, too, but I saw Judge Brannon to sign some search warrants yesterday and, although we didn't talk about this case, he mentioned how full his schedule was. I don't know that he is going to be inclined to move it, especially in light of Jane Doe #1's status. I am wondering if you think it is possible for us to finalize things without going back to court? Brad now has our complete packet and I think if we can get things resolved over the next week, then we can take the settlement conference off the calendar and move on to asking Judg

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