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?
I. Sánchez
Counselor to the United States Attorney
United States Attorney's Office
99 N.E. 4th Street, Suite 800
Miami, FL 33132
-----Original Message-----
From: Paul Cassell [mailto:cassellp@law.utah.edu]
Sent: Thursday, December 01, 2011 2:22 PM
Cc: Brad Edwards
Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today?
and Co.,
Thanks for the call. Sorry I was on the other line.
EFTA00206148
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
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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-----Original Message-----
From: Paul Cassell
Sent: Thursday, December 01, 2011 11:25 AM
To:
(USAFLS)';
Cc: 'Brad Edwards'
(USAFLS)¹;
(USAFLS)'
Subject: RE: Discovery Issues in Epstein
EFTA00206149
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.
Sincerely,
Paul Cassell
Co-Counsel for Jane Doe #1 and Jane Doe #2
Paul G. Cassell