Epstein Secrets

the Rights of Jane Doe #1 and Jane Doe #2 Dear Dexter: First, as mentioned before, please feel free to call me "Siii rather than "Judge Cassell." Brad Edwards and I hope to build a close and friendly working relationship with you as we proceed with our efforts to protect victims' rights. Also, if you could

Doe #1's and Jane Doe #2's efforts that past year-and-a- half to obtain information from Epstein relevant to their CVRA case. And during that time, Bradley J. Edwards and I have had many formal (and informal) contacts with the U.S. Attorney's Office. Until yesterday, no one in the Office has ever suggested that we

lly request the same conferral rights that you gave Mr. Epstein with the First Assistant, the U.S. Attorney, and (if necessary) CEOS. Finally, Mr. Edwards and I stand ready to work with you to narrow the range of issues under consideration in this case. The newly-revealed e-mails appear to make it clea

for these courts (including courts of this Circuit). See, e.g., In re Stewart (I Ph Cir. 2008) (CVRA enforcement action commenced by motion); In re Antrobus (10th Circuit 2008) (same); In re Dean (5th Cir. 2008) (same). Indeed, in an important case in the District of Montana involving enforcement of vict

tecting the Rights of Jane Doe #1 and Jane Doe #2 Dear First, as mentioned before, please feel free to call me "Paul" rather than "Judge Cassell." Brad Edwards and I hope to build a close and friendly working relationship with you as we proceed with our efforts to protect victims' rights. Also, if ou copy

Doe #1's and Jane Doe #2's efforts that past year-and-a- half to obtain information from Epstein relevant to their CVRA case. And during that time, Bradley J. Edwards and I have had many formal (and informal) contacts with the U.S. Attorney's Office. Until yesterday, no one in the Office has ever suggested that we

lly request the same conferral rights that you gave Mr. Epstein with the First Assistant, the U.S. Attorney, and (if necessary) CEOS. Finally, Mr. Edwards and I stand ready to work with you to narrow the range of issues under consideration in this case. The newly-revealed e-mails appear to make it clea

for these courts (including courts of this Circuit). See, e.g., In re Stewart (I Ph Cir. 2008) (CVRA enforcement action commenced by motion); In re Antrobus (10th Circuit 2008) (same); In re Dean (5th Cir. 2008) (same). Indeed, in an important case in the District of Montana involving enforcement of vict

SERVICE LIST Jane Does 1 and 2 I. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., F E-mail: [email protected] Paul G. Cassell Attorneys for Jane Doe # 1 and Jane Doe # 2 22 EFTA00205623

istrict Court, Southern District of Florida Brad Edwards, Esq., F E-mail: [email protected] Paul G

iscuss ... allegations of criminal acts and [DOJ's] decisions to prosecute or not prosecute') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve

istrict Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing, Paul G. Cassell

SERVICE LIST Jane Does 1 and 2 I. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing, Paul G. Cassell Attorneys for Jane Doe # 1 and Jane Doe # 2 37 EFTA00205660

iscuss ... allegations of criminal acts and [DOJ's] decisions to prosecute or not prosecute') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve

espectfully submits this Consolidated Reply in Opposition to Defendant's Letters, Construed as Motions to Disqualify Professor Paul Cassell and Mr. Edwards from Representing Ms. For the reasons set forth below, this Court should deny both of Defendant's Letter Motions, and grant Professor Cassell and

Vice) S.J. Quinney College of Law, University of Utah 383 S. University Street Salt Lake City, Utah 84112 (801) 858-5202 [email protected] Bradley J. Edwards (Seeking Pro Hac Vice) FARMER, JAFFE,WEISSING, EDWARDS, FISTOS & LEHRMAN, ■. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 (954) 5

. United States, 134 S. Ct. 1710 (2014) (arguing before the Supreme Court on behalf of "Amy," a child pornography victim seeking restitution); In re Antrobus, 519 F.3d 1123 (10th Cir. 2008) (arguing for opportunity for victim to deliver a victim impact statement). His previous experience will be valuable

SERVICE LIST Jane Does I and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820

tes, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: brad@pathtoj

scuss ... allegations of criminal acts and [DDT's] decisions to prosecute or not prosecute"') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve

SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the University of Utah Attorneys

tes, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe # 1 and Jane Doe # 2 36 EF

scuss ... allegations of criminal acts and [DDT's] decisions to prosecute or not prosecute"') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve

SERVICE LIST Jane Does I and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820

tes, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: brad@ipathto

scuss ... allegations of criminal acts and [DOJ's] decisions to prosecute or not prosecute"') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve

d intervenors. Jane Does I and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fax: E-mail:

tes, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fax: E-mail: Paul G. Cassell S.J. Quinney College of L

scuss ... allegations of criminal acts and [DDT's] decisions to prosecute or not prosecute"') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve

ents of the NPA as early as October of 2008. She was also provided pro bono counsel with the assistance of the Government prior to her retaining Mr. Edwards, see Villafana Declaration, Dkt. 14 at pg 4, Motion at 25 ("the Special Agents have said that they explained that Epstein would plead guilty to sta

delphia fraud case and stating that "the CVRA does not grant victims any rights against individuals who have not been convicted of a crime"); In re Antrobus, 563 F.3d 1092, 1099 (10th Cir. 2009) (stating that "the purpose of the CVRA is to permit victim participation in ongoing criminal matters"); In re