Epstein Secrets

uld choose the more expansive interpretation. Not only is the CVRA "remedial legislation" that should be broadly construed to achieve its purposes, Edwards v. Kia Motors of America, Inc., 554 F.3d 943, 948 (11th Cir 2008), but the sponsors of the CVRA stated that the right to confer was "intended to be

an appropriate briefing schedule and hold a hearing on the appropriate remedy for those violations. DATED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, 27 EFTA00178083 Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05/02/2011 Page 28 of 29

eed additional facts, evidence, or there's going to be a stipulation submitted to me upon which I can rely. MR. EDWARDS: Sure. Your Honor, this is Brad Edwards. I believe that you do have a sufficient record, in that I don't think that -- I think that we're in agreement that additional evidence does not ne

th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside the grand jury room."); see also Miller v. Mehltretter, 478 F. Supp. 2d 415 (W.D. N.Y. 2007). The fact that Epstein's actions are not protected grand jury matters is further proven by the fact that the

From: Paul Cassell To Brad Edwards Subject: RE: Rule 6(e) Material?? Date: Wed, 13 Apr 2011 14:23:30 +0000 Importance: Normal Dear Thanks very much for not opposing our extra time

From: Paul Cassell To Brad Edwards Subject: RE: Rule 6(e) Material?? Date: Wed, 13

e Epstein and Goff that had nothing to do with the inner workings of the grand jury. There is abundant caselaw to that effect. See, e.g., Miller v. Mehltretter, 478 F. Supp. 2d 415 (W.D. N.Y. 2007) (Grand jury secrecy rule did not prohibit FBI special agent from testifying, in contempt proceedings against

s response? From: Paul Cassell [mailto Sent: Wednesday, April 13, 2011 10:24 AM To: (USAFLS); Subject: RE: Rule 6(e) Material?? Dear (USAFLS); Brad Edwards Thanks very much for not opposing our extra time and pages request. We appreciate your help on those. Brad and I are also digesting your various p

t: RE: Rule 6(e) Material?? Dear (USAFLS); Brad Edwards Thanks very much for not opposing our extra time

e Epstein and IIII that had nothing to do with the inner workings of the grand jury. There is abundant caselaw to that effect. See, e.g., Miller v. Mehltretter, 478 F. Supp. 2d 415 (W.D. N.Y. 2007) (Grand jury secrecy rule did not prohibit FBI special agent from testifying, in contempt proceedings against