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Counselor to the United States Attorney

United States Attorney's Office

99 N.E. 4th Street, Suite 800

Miami, FL 33132

Hi and Co.,

Thanks for the call. Sorry I was on the other line.

Can we set up a time certain? That way Brad can participate.

He is in a depo until 4:30, but should be free at 5 PM your time today (Thursday). Does that work?

Looking forward to chatting. PC

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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332 South 1400 East, Room 101

Salt Lake City, UT 84112-0730



http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell,Paul

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-----Original Message-----



From: Paul Cassell

Sent: Thursday, December 01, 2011 11:25 AM



Cc: 'Brad Edwards'

Subject: RE: Discovery Issues in Epstein

Dear Mr.

We will shortly be filing a motion to compel Government responses to our discovery requests -- discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay. But if the Government's position is rejected on those motions, then the next issue is what discovery can we expect to receive from the Government.

If the motions are denied, will the Government voluntarily produce anything to us? Will the government at least agree to produce the following:



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(1) The Government's initial disclosures pursuant to Fed. R. Civ. P. 26;

(2) Answers to all of the victims' requests for admission;

(3) All documents, correspondence, and other information that the Government distributed to persons or entities outside of the federal Government or received from persons or entities outside of the federal government; and

(4) All documents, correspondence, and other information covered by the victims' discovery request that is not subject to a claim of privilege.

And, for all other information withheld, will the Government agree to produce a document-by-document privilege log, as required by the local rules?

Thanks for your help on these questions and Brad and I have.

Sincerely,

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

332 South 1400 East, Room 101

Salt Lake City, UT 84112-0730



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

EFTA00206102

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.

<table><tr><td>From:</td></tr><tr><td>Sent:</td></tr><tr><td>To:</td></tr><tr><td>Cc:</td></tr><tr><td>Subject:</td></tr></table>

Brad Edwards <

Thursday, December 01, 2011 5:04 PM

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

[ ] , [ ] (USAFLS)

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

11:15 is good for me.

## Brad Edwards

Civil Justice Attorney

Farmer, Jaffe, Weissing,

Edwards, Fistos & Lehrman, P.L.

425 North Andrews Avenue, Suite 2

Fort Lauderdale, Florida 33301

Telephone:

Facsimile:

Toll-free: 1-



www.pathtojustice.com




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