Epstein Secrets

on lift of stay by 11 th Circuit]) Box #2 P-008364 Thru P-008382 File folder entitled "Lacerda Immunity Request" containing internal memoranda, Justice Department documentation, and subpoena regarding immunity request 6(e) Work Product Deliberative Process Investigative privilege Box #2 P-008383 Thru P

ated December 16 and 17, 2010, with attached letter from Paul Cassell to Wifredo A. Ferrer, dated December 10, 2010 Page 23 of 23 EFTA00191236 U.S. Department of Justice United States Attorney Southern District of Florida 500 S. Ausfrallan Ave, Ste 400 West Palm Beach, FL 33401 (561)820-8711 Facsimile: (561)820-

reement Thrown Out," with attorney's notes written on margin Ally work-product Suppl. Box 3 P-013838 Thru P-013841 Letter from Paul Cassell to Wifrcdo A. Ferrer, December 10, 2010, Subject: Request for Investigation of Jeffrey Epstein Prosecution, with underlines, written notes, and comments by DOJ attor

sed "undisputed material facts" are in fact disputed and, in many cases, wrong. 2The U.S. Attorney's Office also repeatedly reminded Mr. Cassell of the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rule of Professional Conduct on the SpecialResponsibilitie

rly viewed as a "civil" case. 6 EFTA00230125 1 Case 9:08-cv-80736-KAM Document 49 Entered on FLSD Docket 03/21/2011 Page 7 of 10 • Letter from Wifrcdo A. Ferrer to Paul G. Cassell (March 15, 2011).3 Accordingly, the victims were left with no choice but to file a motion without stipulated facts. Contemporaneo

sed "undisputed material facts" are in fact disputed and, in many cases, wrong. 2The U.S. Attorney's Office also repeatedly reminded Mr. Cassell of the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rule of Professional Conduct on the SpecialResponsibilitie

se. 6 08-80736-CV-MARRA 000879 EFTA00230703 1 • Case 9:08-cv-80736-KAM Document 49 Entered on FLSD Docket 03/21/2011 Page 7 of 10 Letter from Wifrcdo A. Ferrer to Paul G. Cassell (March 15, 2011).3 Accordingly, the victims were left with no choice but to file a motion without stipulated facts. Contemporaneo