EFTA00205143.pdf

From: Paul Cassell <I To: :=rUSAFLS" , Brad Edwards Cc: " USAFI gallt >, (USAFLS)" Subject: RE: Replies and Responses Due on January 6, 2012 Date: Fri, 06 Jan 2012 15:40:56 +0000 Importance: Normal 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: 1. 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. 2. 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 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) [mailto: Sent: Thursday, January 05, 2012 5:24 PM To: Paul Cassell. Brad Edwards Cc: (USAFLS); (USAFLS) Subject: Replies and Responses Due on January 6, 2012 Paul and Brad, Happy New Year. I need to ask if you have an objection to the government seeking a second enlargement of time, up to Tuesday, January 24, 2012, to file replies to the victims' two responses to the government's motion to dismiss and motion EFTA00205143 to stay discovery, and responses to the victims' protective motion to compel and protective motion for remedies. is preparing for an evidentiary hearing in a 28 U.S.C. 2255 motion, which is scheduled for January 24, 2012. I am scheduled to go to trial in a tort case sometime during the two week trial period commencing January 17, 2012. I have spent most of the preceding two weeks getting ready for the trial. My colleague with sporadic assistance from and I, will be preparing the responses and replies. Please let me know if you have any objections. Thanks. EFTA00205144