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Correspondence · Feb. 3, 2012

Email exchange between Paul Cassell and prosecutors on filing motions, Feb 2012

Subject: RE: government position?

Date: Fri, 03 Feb 2012 01:02:06 +0000

Importance: Normal

Yes. I will respond to Cassell. Have a good trip.

From: (USAFLS)

Sent: Thursday, February 02, 2012 7:55 PM

To: (USAFLS)

Cc:

(USAFLS)

Subject: FW: government position?

I don’t know why he keeps sending these to me or leaving you off the emails. Can you respond? I will be traveling and at the Bar’s Professional Ethics Committee meeting in Orlando tomorrow.

Thanks,

From: Paul Cassell [mailto:

Sent: Thursday, February 02, 2012 7:43 PM

To: . (USAFLS); Brad Edwards

Cc: (USAFLS)

Subject: RE: government position?

Sorry to rush you, but following up on our email from a couple of days ago, Brad and I are hoping to file tomorrow

(1) Our motion for order directing government to file redacted, unsealed pleadings in the public court file (all three of your sealed pleadings); and

(2) A motion for the court to deny the motion to dismiss without requiring additional pleadings from us or, at a minimum, ti grant leave to file a sur-reply (we propose that our brief be of the same length as yours and due 4 weeks after the court rules on our motion (1) above).

I know there may be a “clearance” process there on this case, but hoping you can give us a position by, say, noon Friday? Thanks in advance for your help.

Paul Cassell

Co-counsel for Jane Doe #1 and Jane Doe #2

EFTA00204877

Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah

http://www.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.

From: . (USAFLS) [mailto:]

Sent: Friday, January 27, 2012 5:14 PM

To: Paul Cassell; Brad Edwards

Cc: (USAFLS)

Subject: Reply re Motion to Dismiss

Hi Paul and Brad – I apologize, I didn’t get email because I have been in trial prep. Here is the reply without the attachments. Brad should have received the complete documents today in the mail. The attachments are the complaints and amended complaints from the E.W. and L.M. state court litigation.

I have encrypted the file because of the 6(e) material. I will send the password to Brad separately. Paul – if you want to give me a number where I can send you a text, I can text to you or leave you a voicemail with the password.

EFTA00204878

Email exchange between Paul Cassell and prosecutors on filing motions, Feb 2012

Emails and letters

DOJ Epstein Files, Data Set 9 · Feb. 3, 2012

Subject: RE: government position? Date: Fri, 03 Feb 2012 01:02:06 +0000 Importance: Normal Yes. I will respond to Cassell. Have a good trip. From: (USAFLS) Sent: Thursday, February 02, 2012 7:55 PM To: (USAFLS) Cc: (USAFLS) Subject: FW: government position? I don’t know why he keeps sending these to me or leaving you off the emails. Can you respond? I will be traveling and at the Bar’s Professional Ethics Committee meeting in Orlando tomorrow. Thanks, From: Paul Cassell [mailto: Sent: Thursday, February 02, 2012 7:43 PM To: . (USAFLS); Brad Edwards Cc: (USAFLS) Subject: RE: government position…