EFTA00205591¶
| From: | Paul Cassell [mailto:] |
|---|---|
| Sent: | Friday, January 06, 2012 10:41 AM |
| To: | (USAFLS); Brad Edwards |
| Cc: | (USAFLS); . (USAFLS) |
| Subject: | RE: Replies and Responses Due on January 6, 2012 |
Hey¶
As you know, we’re happy to try and be accommodating. We would be glad to consent to additional time, but would ask in exchange for two things:¶
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The various delays mean that several motions have now been (or will shortly be) pending for more than 90 days, triggering a 90 day report obligation under the local rules. We would trust you would be willing to file that with Judge Marra.
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When we finished our telephone call with you some weeks back, Brad and I understood that we would be receiving (a) some initial discovery in the case and (b) a list of additional discovery that we could expect if your motion to dismiss is denied. But we have yet to receive anything at all regarding discovery. We would trust that you will carry through on what we understood you had agreed to in the telephone call.
Again, we are happy to help - but would ask you to help us on these two points. Thanks!¶
Paul Cassell¶
Co-counsel for Jane Doe #1 and Jane Doe #2¶
Paul G. Cassell¶
Ronald N. Boyce Presidential Professor of Criminal Law¶
S.J. Quinney College of Law at the University of Utah¶
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