EFTA00211120.pdf

From: ' (USAFLS)" To: 1=6•1..,S " k (USAFLS)" Subject: RE: Proposed Joint Status Report and Motion to Reset Briefing and Discovery Schedule Date: Thu, 25 Aug 2016 18:03:11 +0000 Importance: Normal I agree on waiting. I'm not sure whether we need anything from petitioners. Perhaps some requests for admissions? From: (USAFLS) Sent: Thursday, August 25, 2016 1:41 PM To: . (USAFLS) ca; (USAFLS) Subject: RE: Proposed Joint Status Report and Motion to Reset Briefing and Discovery Schedule I vote for waiting to see what else they want to discover from the government. Insofar as discovery to the petitioners, do we need information from petitioners to support our cross-motion? From: (USAFLS) Sent: Thursday, August 25, 2016 1:35 PM To: (USAFLS) (USAFLS) < EM> Subject: FW: Proposed Joint Status Report and Motion to Reset Briefing and Discovery Schedule Please see below. Do you want to wait and see what they are or start drafting some discovery ourselves? Assistant U.S. Attorney Southern District of Florida From: Paul Cassell [ Sent: Thursday, August 25, 2016 11:26 AM To: (USAFLS) ; Brad Edwards Subject: RE: Proposed Joint Status Report and Motion to Reset Briefing and Discovery Schedule Hey Marie, Brad and I have been working on one additional set of discovery requests for the Government. We didn't want you to sign off on a schedule before you had a chance to review those and factor those into whatever schedule you want — i.e., we didn't want to sandbag you with those. We should have those finalized in the next few hours and will send you way. At that point, we're good with the proposed schedule — but we wanted you to have the requests before signing off. As for settlement, Brad is handling those issues and he's always glad to talk to see if there is any progress. Paul Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law University Distinguished Professor of Law EFTA00211120 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: (USAFLS) [ma ilto:Ann.Marie.C.Villafana@usdoj.gov] Sent: Thursday, August 25, 2016 8:42 AM To: Paul Cassell •c > Brad Edwards Subject: FW: Proposed Joint Status Report and Motion to Reset Briefing and Discovery Schedule Hi guys — I never got a response on filing this. Can you advise if it is okay? Also, if we think that settlement is still a possibility, we should try to move on that sooner rather than later, since we are telling the judge that we are working on it. Thanks. I Assistant U.S. Attorney Southern District of Florida From: (USAFLS) Sent: Monday, August 22, 2016 12:04 PM To: 'Paul Cassell' Cc: (USAFLS) >, (USAFLS) <I M> Subject: Proposed Joint Status Report and Motion to Reset Briefing and Discovery Schedule ; Brad Edwards Hi Paul and Brad — To follow up on Paul's emails, I have drafted the attached. Please let me know if it is alright to file. Best regards, Marie Assistant U.S. Attorney Southern District of Florida EFTA00211121