EFTA00206129¶
-----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:¶
(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.¶
EFTA00206130¶
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¶
Email: cassellp@law.utah.edu¶
http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell,Paul¶
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Wednesday, January 04, 2012 8:27 PM¶
Jane Doe litigation¶
&¶
Can you confirm that the plaintiffs in the cases cited below are the petitioners in our CVRA matter?¶
EFTA00206131¶
First Am. Compl. 32-33, Doe Epstein, Case No. 08-80893-CIV-MARRA (“assert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 § 2255] and the [Non-Prosecution] agreement between the Defendant, Jeffrey Epstein, and the United States Government”); Compl. 19-20, L.M. Epstein, Case No. 09-81092-CIV-Cohn (asserting that plaintiff was “covered by” provisions of the Non-Prosecution Agreement between the government and Epstein and that Epstein was thus “estopped by his plea and agreement with the Federal Government from denying the acts alleged in [the] Complaint, and must effectively admit liability to the Plaintiff, L.M., including admitting liability for all counts enumerated in this Complaint”)¶
Thanks,¶
[ ] . (USAFLS) AVillafana@usa.doj.gov¶
Friday, January 06, 2012 11:32 AM¶
RE: Replies and Responses Due on January 6, 2012¶
I think there may be at least one motion that is fully briefed that wasn’t addressed at the hearing – Epstein’s Motion to Intervene. I will look at the docket sheet and figure this out. I still think that we are beyond the 90 days +14, so let me check.¶
A. Villafaña¶
Assistant U.S. Attorney¶
500 S. Australian Ave, Suite 400¶
West Palm Beach, FL 33401¶
From: [blank], [blank] (USAFLS)¶
Sent: Friday, January 06, 2012 10:52 AM¶
To: [black rectangle], [black rectangle] (USAFLS); [black rectangle], [black rectangle]. (USAFLS)¶
Subject: Re: Replies and Responses Due on January 6, 2012¶
Don’t the 90-day notices only kick in after a motion is fully briefed?¶