EFTA00209099.pdf

From: Brad Edwards <1 To: "Lee, (USAFLS)" ctl k Paul Cassell <I Cc: (USAFLS)" <1 Subject: RE: (1) any more production; (2) VR materials Date: Fri, 16 May 2014 20:22:51 +0000 Importance: Normal Inline-Images: image001.png; image002.png; image007.jpg; image008.jpg; image009.jpg; image010.jpg [=. I Is there someone else that I should speak with on these matters? If so, please let me know who that is. Otherwise, I am still hopeful that you can tell me when I should receive the remaining emails/correspondence/material that should have been produced, and also that we can discuss this case before too many more pleadings are filed. Have a nice weekend. Farmer, Jaffe, Weissing, Edwards, Fistos a Lehrman, P.L. Brad Edwards Trial Attorney Toll Free. I wvvw.pattitojustice.com 0000002) From: Brad Edwards Sent: Wednesday, May 14, 2014 12:56 PM To: ,1 111USAFLSI; Paul Cassell Cc: I. (MAAS) Subject: RE: (1) any more production; (2) VR materials l=t First, I have reviewed all that has been produced and it is quite obvious (especially after comparing what was produced to us by Epstein in 2010) that there is a large volume of emails and other correspondence that has not been produced. So, preliminarily, can you give us a timetable on when you think you will be making that production? Second, after reviewing everything and given the tremendous respect I have for I think it would be very beneficial to set up a conference call with at least the four of us very soon (no later than next week if possible). Ultimately I understand that we may need to involve others in the discussions but initially I am hopeful that we can accomplish a lot, just the four of us. If you are amenable, then please give us a few dates within the next week when you can talk. EFTA00209099 Sincerely, Farmer, Jaffe, Weissing, Edwards, Fistos Et Lehrman, P.L. Brad Edwards Trial Attorney Toll Free: Ce www.pathtojustice.com From: Lee, (USAFLS) Sent: Wednesday, May 07, 2014 1:54 PM To: Paul Cassell• Brad Edwards Cc: a, I. (USAFLS) Subject: RE: (1) any more production; (2) VR materials Paul and Brad, The government has not produced all the correspondence requested. I am working on correspondence between Epstein's attorneys and the Child Exploitation and Obscenity Unit, which I should be able to e-mail tomorrow. is also working on additional material to be produced. Finally, there may be responsive materials from the DAG's office, which is different from what we produced to you on May 2, 2014. I will check to see if we have any documents regarding From: Paul Cassell fmailto Sent: Wednesday, May 07, 2014 10:45 AM To: Lee, (USAFLS); Brad Edwards Subject: RE: (1) any more production; (2) VR materials Dear M. We are writing for two reasons. First, we would like to confirm that you have produced all the correspondence that we have requested — that you're not contemplating any more production. Second, we now represent in her capacity as a crime victim. As such, we are requesting her 302's and all other information you have gathered with respect to her. Thanks for your help on this. Paul Cassell and Brad Edwards for Jane Doe #1, Jane Doe #2, and EFTA00209100 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 Voice: Fax: Email: http://www.law.utah.edu/profiles/default.asp7PersonID=S7&name=Cassell Paul You can access my publications on http://ssrn.com/author=30160 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, 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. Professor Cassell is admitted to the Utah State Bar, but not the bars of other states. Thank you. From: Paul Cassell Sent: MODSMay 05, 2014 8:22 AM To: Lee, (USAFLS); Brad Edwards ( Subject: RE: Jane Does No. 1 and 21 United States - Production of Documents - is one missing? Hi Brad and I wanted to thank you for producing the correspondence last Friday. We're sure that was a lot of work, and we appreciate you getting that to us in a timely fashion. Brad and I wanted to double check with you. The first file that we received was identified as RFP_2. We never received an RFP_1. In total we received eight files, as the title of your email suggested we would. The eight were: RFP_2 RFP_3_part_I RFP_3_part_II RFP_3_part_III RFP_5_Redacted RFP_8 RFP_19 RFP_mis Should we have received anything else? Specifically, should we have received an RFP_1? Thanks you in advance for darifying this point. Brad and I are working on a filing in response to the Epstein Motion for Protective Order that we may need to file in the next 24 hours, so we'd appreciate clarity on this point soon. Thanks again for all your help. Paul Cassell and Brad Edwards 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 S. 1400 E. , Room 101 Salt Lake City. UT 84112-0730 (phone) (fax) You can access my publications on http://ssm.com/author=30160 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, 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. Professor Cassell is admitted to the Utah State Bar, but not the bars of other states. Thank you. From: Lee, (USAFLS) Sent: Friday, May 02, 2014 1:35 PM EFTA00209101 To: Paul Cassell; Brad Edwards ( Subject: Jane Does No. 1 and 2 United States - Production of Documents, One of Eight Paul and Brad, I will be sending you eight (8) files, broken into several e-mails. I have not gone through the Child Exploitation and Obscenity Section (CEOS) files, although I have included the May 15, 2008 letter from the CEOS Chief advising Epstein's attorneys that the United States Attorney was acting within his discretion in prosecuting the case. On the documents pertaining to Epstein's appeal to the Deputy Attorney General's Office, the documents produced are copies provided to our Office. There may be more at the Deputy Attorney General's Office, which has been notified of the Eleventh Circuit's decision. EFTA00209102