Epstein Secrets

with handwritten Suppl. Box 3 P-013937 Thru P-013939 Draft Letter, to Professor Paul Deliberative Process Privilege Attorney Work Product G. Cassell, with handwritten corrections Suppl. Box 3 P413940 Thru P-013942 Draft Letter, marked "Confidential: To O ned b Addressee Only," , with handw

Document 361 Entered on FLSD Docket 02/10/2016 Page 1 of 57 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-cv-80736-KAM JANE DOE 1 AND JANE DOE 2, Petitioners, UNITED STATES, Respondent. JANE DOE 1 AND JANE DOE 2'S CONSOLIDATED STATEMENT OF UNDISPUTED MATERIAL FACTS AND MOTI

m letter to Jane Doe 5 also acknowledged the victims' rights under the CVRA at the same time as the Office was not disclosing the NPA's existence to Jane Doe 5 and the other victiim."6 101. In mid-June 2008, Mr. Edwards contacted the line AUSA handling the case to inform her that he represented Jane Doe 1 a

ECF on this 28th day of June, 2010: Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman PL Fort uder ale FL 3301 Phone: Fax: G. Cassell, Esq. Pro Hac V t Lake Ci , UT 84112 Fax o-counse or Plaintiff Jack Alan Goldberger, Esq. s, P.A. ach, FL 33401-5012 Co-Counsel for Defendant

atement of Undisputed Facts. 12 EFTA00725980 In addition, if Epstein had thought that there was some improper coercion involved in, for example, Jane Doe's case, his remedy was to raise the matter before Federal District Court Judge Kenneth A. Marra who was presiding over the matter. Far from raising an

herine Warthen Ezell [email protected], mestrada®podhurst.com Michael James Pike [email protected], bobbie@bcklawcom, [email protected] Paid G. Cassell [email protected] Robert Deweese Critton , Jr rcrit®bc1claw.com, [email protected] EFTA00207443 9:08-cv-80893-KAM Notice has not been deli

ponse/Reply re [146] Plaintiffs MOTION for Leave to File Jane Doe No. 103's Motion for Leave to File Brief as Amicus Curiae in Support of Plaintiff Jane Doe's Opposition to Defendant Epstein's Motion for Summary Judgment and Certification of Having C. Replies due by 5/21/2010. Signed by Judge Kenneth A. M

A proposed Amended Scheduling Order is attached. Respectfully submitted, Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY slPaul G. Cassell Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Cit Utah 84112 COUNSEL FOR PETITIONERS By: COU

dale, FL 33301-3268 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Cit Utah 84112 Attorneys for Jane Doe # 1 and Jane Doe # 2 EFTA00211159

t spirit, attached is a courtesy copy of one of the pleadings we plan to file on Monday. IM Cassell Co-Counsel for Jane Doe #1 and Jane Doe tt2 MI G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Quinney College of Law at the University of Utah http://www.law.utah.eduiprofilesidefault.a

n close contact with you. In that spirit, attached is a courtesy copy of one of the pleadings we plan to file on Monday. IM Cassell Co-Counsel for Jane Doe #1 and Jane Doe tt2 MI G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Quinney College of Law at the University of Utah http://

. The judge left open what the possible remedy could bef1321 v. Epstein (2015) In a December 2014 Florida court filing by Bradley Edwards and Pa.ul G. Cassell meant for India the Crime Victims Rihis uit,[14°) (then known as , alleged in a sworn affidavit that at age 17, elae had. beep:" sexually tra

014)*5C: 1. • — r. • .L% A Deeeneher so, 2034, federal civil salt was filed in Florida fry Jane Doe s k. -11 V.; El‘..:71 t. ar tc caa, and Jane Doe 2 egainst the United States for violations of the Crime "Mims' iRig is ctby the ailment of J.Isathys NBA with Ensteba and his limited 205/Cite plea.

ssible remedy could beig9i Virginia Giuffre v. Epstein (2015) In a December 2014 Florida court filing by Bradley Edwards External video and Panl. G. Cassell meant for inclusion in the Crime Victims g where are they now? The Rights' Act LawsnitP4.91 ykrzipia. Giuffre (then known as biggest players In th

4-5Cr-0 A L e 13)56 StNG pitom 1.\)e<ri Pos iTICAva A December 3o, 2014, federal civil suit was filed in Florida by Jane Doe i (Courtney Wild) and Jane Doe 2 against the United States for violations of the Crime Victims' Rights Act by the Department of Justice's NPA with Epstein and his limited 2008 stat

Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 7 of 8 G. Cassell Attorney for Petitioners Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: Facsimile: E-Mail: Jay C. Howell, Esquire Attorney

E I HEREBY CERTIFY that on October 16. 2008, I electronically filed the foregoing document with the Clerk of the Court using CMJECF. SERVICE LIST Jane Doe 1 and Jane Doe 2 Case No.: 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Assistant U.S. Attorney 99 N.E. 4t

e to anyone—including Epstein’s victims. As a consequence, the victims were not told about the NPA. 16. On July 7, 2008, a young woman identified as Jane Doe No. 1, one of Jeffrey Epstein’s victims (other than Giuffre), filed a petition to enforce her rights under the Crime Victims’ Rights Act (“CVRA”), 18

ng this information along to Joan, who will add this information into our contacts list. Thanks for your interest in this important case. Paul 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