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Correspondence · Dec. 2011

Prosecutor emails with victims' counsel on sealed motion-to-dismiss response, Dec 2011

EFTA00206062

Mid morning is fine for me.

From: [blank], [blank] (USAFLS)

Sent: Thursday, December 08, 2011 4:20 PM

To: , . (USAFLS); , . (USAFLS)

Subject: Re: Jane Does US — Sealed Response to Motion to Dismiss

Would mid-morning (about 10:30) work for everyone, or do you have another preference?

From: [blank], [blank], [blank]. (USAFLS)

Sent: Thursday, December 08, 2011 04:16 PM

To: , (USAFLS); , (USAFLS)

Subject: Re: Jane Does US — Sealed Response to Motion to Dismiss

From: □, □ (USAFLS)

Sent: Thursday, December 08, 2011 04:09 PM

To: [blank], [blank] (USAFLS); [blank], [blank]. (USAFLS)

Subject: RE: Jane Does US — Sealed Response to Motion to Dismiss

Let’s do it tomorrow. I will have my Blackberry on. I believe our replies are due on December 15.

I am set to go to trial before Judge Ungaro during the two week term commencing January 16, 2012. She just denied my motion for continuance, so it looks like the case is going forward.

From: [blank], [blank] (USAFLS)

Sent: Thursday, December 08, 2011 4:02 PM

To: [ ] , [ ] (USAFLS); [ ] , [ ] . (USAFLS)

Subject: Re: Jane Does US — Sealed Response to Motion to Dismiss

I’m actually out of the office today on sick leave. If you want to talk today, I can call in, but I have not yet had a chance to review the sealed pleading and I was not inclined to forward the sealed document

EFTA00206063

to my gmail account.

Let me know what you both prefer.

From: □, □ (USAFLS)

Sent: Thursday, December 08, 2011 03:54 PM

To: , (USAFLS); . (USAFLS)

Subject: RE: Jane Does US — Sealed Response to Motion to Dismiss

I will be out of the office tomorrow, but I can call in. Do you want to try something today?

From: [blank], [blank] (USAFLS)

Sent: Thursday, December 08, 2011 3:39 PM

To: [ ] , [ ] . (USAFLS); [ ] , [ ] (USAFLS)

Subject: Re: Jane Does US — Sealed Response to Motion to Dismiss

Can all three of us get together on the phone tomorrow?

From: [blank], [blank], [blank]. (USAFLS)

Sent: Thursday, December 08, 2011 11:47 AM

To: , (USAFLS); , (USAFLS)

Subject: Jane Does US — Sealed Response to Motion to Dismiss

Hi and Here is the sealed portion of their response. Judge Marra’s clerk called to confirm that we had no objection to the Motion to Seal. I stated that we had no objection.

I am on vacation next week. We really HAVE to get this file transferred to the Middle District.

<<20111206 Sealed Response to Motn to Dismiss.pdf>>

Assistant U.S. Attorney

500 S. Australian Ave, Suite 400

EFTA00206064

West Palm Beach, FL 33401

Sorry I had to leave the call early Friday. Meant to check with you on this then.

I am working with Brad to finalize our pleadings to be filed on Monday in response to the motion to dismiss. We are filing an unsealed pleading (that does not discuss grand jury material) as well as a sealed pleading (that discusses only the grand jury material and related issues). The unseal pleading is 24 pages long and the sealed pleading is 7 pages long.

We also have a response to the motion to stay which is well under the 20 page limit.

Any objection to a motion for the extra pages (4+7, although I’m not sure whether we count the 7) to respond to your motion to dismiss?

Thanks for your help on getting back to us. PC

Paul G. Cassell

Ronald N. Boyce Presidential Professor of Criminal Law

S.J. Quinney College of Law at the University of Utah

332 S. 1400 E., Room 101

Salt Lake City, UT 84112-0730

(phone)

(fax)

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) [

Sent: Thursday, December 01, 2011 3:23 PM

To: Paul Cassell; [ ] . (USAFLS); [ ] , [ ] (USAFLS)

Cc: Brad Edwards

Subject: RE: Conference call 11:15 AM Florida time - Friday

Paul,

We will take care of the arrangements for tomorrow at 11:15 a.m. Thanks.

From: Paul Cassell [mailto: paulcassell@microsoft.com]

Sent: Thursday, December 01, 2011 4:59 PM

To: [email] . (USAFLS); [email] . (USAFLS)

Cc: Brad Edwards; [email] . (USAFLS)

Subject: RE: Conference call 11:15 AM Florida time - Friday

EFTA00206065

Hi all,

Does 11:15 AM Florida time on Friday work?

If so, please call my cell phone as well as Brad – can y’all initiate the conference call or set up a call in number?

Looking forward to chatting. PC

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.

Sent: Thursday, December 01, 2011 2:34 PM

To: [blank], [blank] (USAFLS); Paul Cassell

Cc: Brad Edwards; (USAFLS)

Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today?

Hi everyone – Sorry, I am having a very busy duty week. Tomorrow I have court at 9:00 probably until 11:00 and then again from 3:00 until 5:00. I have a debriefing at 1:00, but I should be able to step out after 1:30. So, 11:15 or 1:30 are best for me, but your schedules take priority.

Assistant U.S. Attorney

500 S. Australian Ave, Suite 400

West Palm Beach, FL 33401

Sent: Thursday, December 01, 2011 3:52 PM

To: Paul Cassell

Cc: [ ] [ ] [ ], [ ] [ ). (USAFLS); [ ], [ ] (USAFLS)

Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today?

Unfortunately, that doesn’t work for us today. Can we set up a time for tomorrow?

Counselor to the United States Attorney

United States Attorney’s Office

99 N.E. 4th Street, Suite 800

Miami, FL 33132

Telephone:

E-mail: <

Prosecutor emails with victims' counsel on sealed motion-to-dismiss response, Dec 2011

Emails and letters

DOJ Epstein Files, Data Set 9 · Dec. 2011

EFTA00206062 Mid morning is fine for me. From: [blank], [blank] (USAFLS) Sent: Thursday, December 08, 2011 4:20 PM To: , . (USAFLS); , . (USAFLS) Subject: Re: Jane Does US -- Sealed Response to Motion to Dismiss Would mid-morning (about 10:30) work for everyone, or do you have another preference? From: [blank], [blank], [blank]. (USAFLS) Sent: Thursday, December 08, 2011 04:16 PM To: , (USAFLS); , (USAFLS) Subject: Re: Jane Does US -- Sealed Response to Motion to Dismiss From: □, □ (USAFLS) Sent: Thursday, December 08, 2011 04:09 PM To: [blank], [blank] (USAFLS); [blank], [blank]. (USAFLS) Sub…