EFTA00212813.pdf

From: Brad Edwards To: Cc: Subject: RE: Jane Does v. U.S. -- Motion to Unseal Date: Thu, 07 Apr 2011 14:16:40 +0000 Importance: Normal Inline-Images: image001.jpg I read the cases. I don't agree with your interpretation of the cases to the extent that you are saying that the dissemination of email correspondence between you and JE's attorneys will somehow avail an argument for JE's attorneys to make that his due process rights have somehow been violated. I started going line by line on your designations, but it is time-consuming and because I don't agree with your interpretation of the cases, I just don't see the point of going through each line and arguing points. Regardless, I have no problem with agreeing to redacting statute numbers as well as personal information (addresses, phone numbers, etc.). I hope this helps. Brad Edwards Civil Justice Attorney Farmer, Jaffe, Weissing, Edwards, Fistos Et Lehrman, P.L. 301 f Become our fan on Facebook Please consider the environment before printing this e-mail. IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a 'reliance opinion' under applicable Treasury Regulations, and accordingly are not intended or written to be used, and may not be used or relied upon, for the purpose of (i) avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or (ii) promoting, marketing or recommending to another party any tax-related matters addressed herein. NOTICE: THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND CONFIDENTIAL. IT IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR. PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE TOLL FREE (800) 400-1098 AND DELETE THE MATERIAL FROM ANY COMPUTER. THANK YOU. From: Sent: Wednesday, April 06, 2011 1:57 PM To: Brad Edwards Cc: Subject: Jane Does v. U.S. -- Motion to Unseal EFTA00212813 Dear Brad: Hope you are doing well. I wondered whether you had a chance to review the In re Smith case, 656 F.2d 1101, that I had discussed with you earlier. Based on that case and its progeny, in particular Senate of the Commonwealth of Puerto Rico v. United States Dep't of Justice, 1992 WL 119127 at •3 (D.D.C. May 13, 1992) and United States v. Anderson, 55 F. Supp. 2d 1163, 1168 (D. Kan. 1999), I believe that the following portions of your Exhibit A should remain under seal (and any related portions of DE48): 005 [words "1512 and 113"] 006-007 008 [paragraph 1 only] 016 [words "403," "113," and "371 conspiracy"] 017-018 019 [paragraph 1 only] 028 [" 1512"] 029 [first 2 paragraphs] 030 [numbered paragraphs 2, 3, and 4] 036 [numbered paragraphs 1(a) and 1(c)] 042 [word "1512"] 045 [word "1512(d), 046-048 049 [paragraph 1] 057 [first sentence] 058 059 [first sentence] 062-063 ["1512"] 064 [paragraph 1] 071 ["1512"] 073 ["1512"] 191 [3rd full paragraph, 3rd and 5th sentences] 192 [4th full paragraph [2nd and 3rd sentences] 300-309 EFTA00212814 310 329-340 350-358 The names and in any copies of the draft NPA Also, do you have any objections to redacting my personal email address and personal cell phone numbers in Bates numbers 005, 016, 026-030, 039, 056, 062, 072, 073, 088, 090, 097-098, 177, 180? You may not know that prisoners have access to PACER. Thank you! Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 EFTA00212815