Epstein Secrets

n filed an emergency petition for enforcement of the CVRA, "seeking an order compelling the Department of Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them various rights conferred upon crime victims under 21 Respondent's Exhibit A Case No. 08-80736-CIV

f Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them

Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: [email protected] Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane D

REC. S7060-01, 157 Cong. Rec. S7060-01, S7060 (daily ed. Nov. 2, 2011) (statement of Sen. Kyl) (quoting his Nov. 2, 2011, letter to Attorney General Holder which, in turn, quotes this Court's decision); see also Paul G. Cassell, Nathanael J. Mitchell & Bradley J. Edwards, Crime Victims' Rights During C

sponsor Senator Kyl wrote two letters in 2011 to Attorney General Holder, specifically raising questions about the Depart

s daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah. 64 EFTA00799951 Case 9:08-cv-80736-KAM Document 416 Entered on FLSD Docket 08/11/2017 Page 65 of 65 CERTIFICATE OF SERVICE I certify that the

n filed an emergency petition for enforcement of the CVRA, "seeking an order compelling the Department of Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them various rights conferred upon crime victims under 21 EFTA00078855 Case 9:08-cv-80736-KAM Documen

f Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them

Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fax: E-mail: Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 Fax: E-mail: Attorneys for Jane Doe # 1 and Jane Doe # 2 54 EFTA00078888

n filed an emergency petition for enforcement of the CVRA, "seeking an order compelling the Department of Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them various rights conferred upon crime victims under 21 EFTA00177071 Case 9:08-cv-80736-KAM Documen

f Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them

mile (954) 524-2822 Florida Bar No.: 542075 E-mail: [email protected] and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: [email protected] Attorneys for Jane Doe #1

ble decision from a court. See, e.g., LaRoque v. Holder, 650 F.3d 777, 791 (D.C. Cir. 2011) (allowing cas

mile (954) 524-2822 Florida Bar No.: 542075 E-mail: [email protected] and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: [email protected] Attorneys for Jane Doe #1

multiple reasons. 1. Epstein is Not a Privilege Holder and Thus is Not Covered by Perlman. 14 EFTA002

425 North Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954) 524-2820 [email protected] Paul G. Cassell S. J. Quinney College of Law at the University of Utah 332 S. 1400 E., Room 101 Salt Lake City, UT 84112 (801) 585-5202 [email protected] Attorneys for Plaintiffs-Appellees Jane Doe No.1 and Jane

multiple reasons. 1. Epstein is Not a Privilege Holder and Thus is Not Covered by Perlman. 14 EFTA002

materials. 20 EFTA00209592 DATED: July 2, 2013 Respectfully Submitted, Is/Paul G. Cassell Paul G. Cassell S.J. Quinney College of Law at the University of Utah and Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Attorneys for Jane Doe No. I and Jane Doe No. 2 21 EFTA00209

in a notorious federal sex abuse case were deprived of the * Ronald N. Boyce Presidential Professor of Criminal Law, S.J. Quinney College of Law at the University of Utah. ** Associate, Snow, Christensen & Martineau (Salt Lake City, Utah). *** Partner, Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman (Fort Lauderda

Shortly after the Department released its opinion, one of the CVRA’s congressional sponsors, then-Senator Jon Kyl, sent a letter to Attorney General Enc Holder strenuously objecting to the Department’s conclusions. Senator Kyl directly stated his view that “[w]hen Congress enacted the ' Scott Campbell, Step

to a criminal defendant in similar circumstances. If prosecutors have sufficient information to provide notice 3 Letter from Jon Kyl, U.S. Sen., to Eric H. Holder, Jr., Att’y Gen. (June 6, 2011), reprinted in 157 Conc. REc. $3608 (daily ed. June 8, 2011) (statement of Sen. Jon Kyl). 4 18 USC. § 3771(c\(1). 5

CASSELL*, NATHANAEL J. MITCHELL** and BRADLEY J. EDWARDS*** * Ronald N. Boyce Presidential Professor of Criminal Law, S.J. Quinney College of Law at the University of Utah. ** Associate, Snow, Christensen & Martineau (Salt Lake City, Utah). *** Partner, Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman (Fort Lauderdal

Shortly after the Department released its opinion, one of the CVRA's congressional sponsors, then-Senator Jon Kyl, sent a letter to Attorney General Eric Holder strenuously objecting to the Department's conclusions. Senator Kyl directly stated his view that "when Congress enacted the [*62] CVRA, it intended t

? It was against that backdrop that Senator Kyl gave the example of conferring about proceedings "after charging." In his letter to Attorney General Holder, Senator Kyl also noted that he had: made clear that crime victims had rights under the CVRA even before an indictment is filed. For example, ... I

t proceedings "after charging." In his letter to Attorney General Holder, Senator Kyl also noted that he had: made clear