EFTA00205152.pdf

From: Paul Cassell <cassell. e law.utah.edu> Cc: Brad Edwards <bedwards®pathtojustice.com> Subject: RE: Redacted Pleading Rather than Sealing the Entire Pleading Date: Thu, 01 Dec 2011 17:48:54 +0000 Importance: Normal We haven't heard back from you on the issue regarding sealing of ' n the Epstein case. (See email below sent earlier this week.) I was hoping that you (o ould get back to Brad and me quickly on this issue. As you know, we have a series of pleadings that we need to file on Monday. We are trying to understand the Government's position on sealing these pleadings. As you also know, we think there is absolutely no basis for sealing the majority of the Government's pleadings. We hope you agree so that we can move forward consensually, at least on this issue. Thank you in advance for your assistance. Paul Cassell Co-Counsel for Jane Doe #1 and Jane Doe #2 Paul G. Cassell 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. Original Message From: Paul Cassell Sent: Monda , November 28, 2011 2:29 PM c: ra war s Subject: RE: Redacted Pleading Rather than Sealing the Entire Pleading EFTA00205152 I am writing as co-counsel in the Jane Doe case. I understand that you are supervising the case for U.S. Attorney's Office there. I am writing to request that the Government file new, redacted copies of its currently pending motion to dismiss and motion for stay. As you may know, the Government has filed these two motions entirely under seal. Yet the vast bulk of both motions do not deal with any material that needs to be under seal. As you may know, Judge Marra has previously unsealed other pleadings in this case, recognizing the considerable public interest in the issues being discussed. As you also know, Jane Doe #1 and Jane Doe #2 have tried to work cooperatively with the Government wherever possible. For example, we earlier stipulated to proposed redactions of material proposed by Ms. Villafana to avoid disclosing information that she viewed as confidential. In light of all this, the victims are writing to inquire whether the Government would file a motion to place redacted copies of its two motions in the public court file in the case. Attached are two redacted pleadings that we believe remove all information that is properly subject to sealing to protect confidential grand jury material - but no more. Please let me know whether the Government is willing to move forward on that basis. Sincerely, Paul Cassell Co-Counsel for Jane Doe #1 and Jane Doe #2 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. EFTA00205153