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efta-efta00014067DOJ Data Set 8Correspondence

EFTA00014067

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EFTA Disclosure
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From: Brad Edwards To: (USAFLS)" c Cc: ' llMaFLS)" k Paul Cassell Subject: RE: Draft Protective Order Date: Fri, 15 Aug 2008 15:58:44 +0000 Importance: Normal Attachments: Protective_Order.Final.doc 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: (USAFLS) (mailto: Sent: Friday, August 15, 2008 11:41 AM To: Brad Edwards Cc: I . (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» EFTA00014067

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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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