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portance: Normal — What is the Government's view on all this? Brad Edwards and Paul Cassell for Jane Doe No. 1 and Jane Doe No. 2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Quinney College of Law at the University of Utah 332 South 1400 East, Room 101 Salt Lake City, UT 84112-0730
the problem with the alternative that you propose is that the jurisdictional issue and the merits issues overlap. You argue as to jurisdiction that Perlman does not apply because there is no privilege. And our argument on the merits is that there is a privilege. So privilege is at the heart of the juris
ks for providing us whatever information you can as soon as you can. Brad Edwards and Paul Cassell for Jane Doe #1 and Jane Doe #2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.). Quinney College of Law at the University of Utah Sent: Friday, June 28, 2013 2:37 PM ofainslibminliall
ay. What is your position on this motion? We understand you are conferring with Washington DO), and hope that they will agree that expansion of the Perlman doctrine is clearly not in the Government's interest. Thanks for providing us whatever information you can as soon as you can. Brad Edwards and Pau
Question Dexter — What is the Government's view on all this? Brad Edwards and Paul Cassell for lane Doe No. 1 and Jane Doe No. 2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Paul , „— CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This mes
the problem with the alternative that you propose is that the jurisdictional issue and the merits issues overlap. You argue as to jurisdiction that Perlman does not apply because there is no privilege. And our argument on the merits is that there is a privilege. So privilege is at the heart of the juris
the Government's EFTA00209340 interest to endorse. Sincerely, Brad Edwards and Paul Cassell for lane Doe ttl. and Jane Doe tt2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Quinney College of Law at the University of Utah 332 South 1400 East, Room 101 Salt Lake City, UT 84112-0730
ircuit decision that an attorney-client rivilege order is not immediately appealable). As you probably know, Epstein plans to rely in United States' Perlman as the basis for an interlocutory appeal. Our understanding is that the Justice Department has long sought to give a narrow construction to Perlman.
ks for providing us whatever information you can as soon as you can. Brad Edwards and Paul Cassell for Jane Doe #1 and Jane Doe #2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Quinney College of Law at the University of Utah 332 S. 1400 E. , Room 101 Salt Lake Ci , UT 84112-0730 (p
ay. What is your position on this motion? We understand you are conferring with Washington DO), and hope that they will agree that expansion of the Perlman doctrine is clearly not in the Government's interest. Thanks for providing us whatever information you can as soon as you can. Brad Edwards and Pau
Entities connected to both Ronald N. Boyce and Perlman

Paul Cassell
PERSON
Bradley Edwards
PERSON
Jeffrey Epstein
PERSONJane Doe
PERSON
the University of Utah
ORGANIZATION
S.J. Quinney College of Law
ORGANIZATION
Salt Lake City
LOCATION
Kenneth Marra
PERSON
United States
LOCATIONMaria Farmer
PERSONQuinney College of Law
ORGANIZATION
Dexter Lee
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSONSouthern District
LOCATION
Alan Dershowitz
PERSONFerrer
PERSONthe Utah State Bar
ORGANIZATIONthe Southern District
LOCATION
Ghislaine Maxwell
PERSON