Subject:	Re: Voluntary Production of Materials?
Date:	Tue, 10 Jan 2012 13:16:17 +0000
Importance:	Normal

When do you want to talk? I'm at physical therapy now, but should be in the office by about 11:15. We can talk then or any time after lunch. I'll pull the online state court dockets today. How can we get certified copies of the complaints in the state cases? Does the office have any mechanism for getting those? **Sent:** Monday, January 09, 2012 05:52 PM Subject: RE: Voluntary Production of Materials? Yes, please. Also, Ed, as to your question on the case numbers. Jane Doe #2’s case number is 50-2008-CA-028051 XXXX MB AB: vs. Jeffrey Epstein, In the Circuit Court of the Fifteenth Judicial Circuit in and for Palm Beach County. That case must have been removed to federal court (the Cohn case that you referenced in your email) and was then remanded to state court. Jane Doe #1 also filed her case in state court – Jeffrey Epstein, Case No. 50 2008 CA 028058 XXXX MB AD, in the Fifteenth Judicial Circuit in and for Palm Beach County. **Sent:** Monday, January 09, 2012 3:43 PM Subject: RE: Voluntary Production of Materials? Should we talk about this? I really have no idea what we have or don’t have that would be responsive to non-objectionable discovery, or what we could do in response to Cassell’s request. From: Paul Cassell [mailto:cassellp@law.utah.edu] Sent: Monday, January 09, 2012 3:31 PM EFTA00205515 'bedwards@pathtojjustice.com' Subject: RE: Voluntary Production of Materials? As mentioned last week, Brad and I wanted to chat with you about where we are on discovery in this case. I spoke with Brad, and while our recollection of what you promised you were going to do may be slightly different than ours, we believe there was at least a general agreement to the spirit of the voluntary production – that is, you were going to cooperate to the extent that you are able. As we explained on our phone call, we requested the things that we would like produced. While you may believe those requests to be overly broad and may assert that legal objection in your responses, you indicated that you would be willing to produce certain documents that may not be all the documents in your possession responsive to the request but that would amount to some documents or materials that we do not yet have. Without making us go through the unnecessary exercise of narrowing our requests, it would be most helpful if you would just shoot us over whatever documents or materials that you are willing to share with us voluntarily. We will agree that whatever production you make does not constitute a waiver of any legal objection you may have to any discovery request. So, are you willing to produce anything to us is, I guess, the bottom line. Thanks for any voluntary help you can extend. Paul Cassell Co-Counsel 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, 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:** Saturday, January 07, 2012 8:08 AM To: Paul Cassell Subject: Re: Replies and Responses Due on January 6, 2012 Thanks. Hope everyone has a great weekend.