Epstein Secrets

y J. Edwards FARMER. JAFFE. WLETSSINrk 17 EFTA00208010 Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05/02/2011 Page 28 of 29 and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane Doe #2 28 EFTA00208011 Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05:022011 Pag

LSD Docket 05/02/2011 Page 28 of 29 and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane

ges. It was at that point (at a minimum) that the Government should have extended to the victims their right to confer. To the same effect is In re Peterson, 2010 WL 5108692 (N.D. Ind. 2010), a case that the Government cites as supporting its position. Gov't Resp. at 21-22. But Peterson squarely rejects

FE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale. Florida 33301 Telephon Facsimile E-mail: And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah' 332 S. 1400 E. Salt Lake it T 4112 Telephon Facsi E-Mai Attorneys for J

33301 Telephon Facsimile E-mail: And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the

ssing the concept in the context of the attorney-client privilege); Baratta v. Homeland Housewares, LLC, 242 F.R.D. 641, 643 (S.D.F1a.2007) (same); Peterson v. Wallace Computer Servs., Inc., 984 F.Supp. 821 (D.Vt.1997) (same). And all other privileges and protections can similarly be waived. II. The Go

red on FLSD Docket 05/02/2011 Page 28 of 29 EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Cit UT 84112 Attorneys for Jane Doe #1 and Jane Doe

. On August 14, 2008, a hearing was held, during which a stipulated set of facts was discussed: THE COURT: So if I can hear from Mr. Edwards or Mr. Cassell first what the Plaintiffs' position [is] as far as where we stand on the record in terms of whether I need additional facts, evidence, or there's g

ges. It was at that point (at a minimum) that the Government should have extended to the victims their right to confer. To the same effect is In re Peterson, 2010 WL 5108692 (N.D. Ind. 2010), a case that the Government cites as supporting its position. Gov't Resp. at 21-22. But Peterson squarely rejects

"civil" case. 6 EFTA00177110 Case 9:08-cv-80736-KAM Document 49 Entered on FLSD Docket 03/21/2011 Page 7 of 10 Letter from Wifredo 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. Contemporaneously with the filin

f the proposed "undisputed material facts" arc in fact disputed and, in many cases, wrong. 'The 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

trict court had no authority under mandatory restitution act to reopen restitution proceedings after sentencing). More recently in the case °fin re Peterson, No. 2:10-CV-298, 2010 WL 5108692 (N.D. Ind. Dec. 8, 2010), the district court denied relief under the Crime Victims' Restitution Act before any ch

nell, 4.66M) had updates on Biden's Cabinet selection process. Biden Reportedly "Leaning Toward" Vilsack For Second Stint At USDA. Politico (12/7, Cassella, Crampton, Pager, 4.29M) reports Biden is "leaning toward picking former Agriculture Secretary Tom Vilsack to return as head of the USDA...turning t

not imposing lockdowns or mask mandates. Liability Protections, State And Local Aid Stall COVID Relief Negotiations. The Wall Street Journal (12/7, Peterson, Duehren, Subscription Publication, 7.57M) says a growing bipartisan group of lawmakers from both chambers has been working out the details of a $90

ortedly "Leaning Toward" Vilsack For Second Stint At USDA. Politico <https://www.politico.com/news/2020/12/07/vilsack-usda-top-choice-443424> (12/7, Cassella, Crampton, Pager, 4.29M) reports Biden is "leaning toward picking former Agriculture Secretary Tom Vilsack to return as head of the USDA...tuming t

f Negotiations. The Wall Street Journal <https://www.wsj.corn/articles/covid-aid-negotiators-grapple-over-liability-protections- 11607382762> (12/7, Peterson, Duehren, Subscription Publication, 7.57M) says a growing bipartisan group of lawmakers from both chambers has been working out the details of a $90

nell, 4.66M) had updates on Biden's Cabinet selection process. Biden Reportedly "Leaning Toward" Vilsack For Second Stint At USDA. Politico (12/7, Cassella, Crampton, Pager, 4.29M) reports Biden is "leaning toward picking former Agriculture Secretary Tom Vilsack to return as head of the USDA...turning t

not imposing lockdowns or mask mandates. Liability Protections, State And Local Aid Stall COVID Relief Negotiations. The Wall Street Journal (12/7, Peterson, Duehren, Subscription Publication, 7.57M) says a growing bipartisan group of lawmakers from both chambers has been working out the details of a $9

iscovery and admissibility as is set forth in the incorporated memorandum. Mr ;LETS DISCUSS - DOES THIS BROADEN THE INTERVENTION - WHAT EXACTLY HAS CASSELL ASKED FOR] Epstein also objects to any further , as-well-as-dieir-Footien-te disseminate the plea negotiation &communications or its content -to th

rict court had no authority under mandatory restitution act to reopen restitution proceedings after sentencing). More recently in the case of In re Peterson, No. 2:10-CV-298, 2010 WL 5108692 (M. Ind. Dec. 8, 2010), the district court denied relief under the CVRA before any charges were filed. The court

tus, E.F. (2000, April) The poet as brain mechanic: A 2050 version of physics for poets. Global Business Network Bulletin, p.1-5. Loftus, E. L. and Castelle, G. (2000) Crashing Memories in Legal Cases. In P.J. van Koppen & N.H.M. Roos (Eds). Rationality, Information and Progress in Law and Psychology. Ma

D.M. & Loftus, E.F. (2009) The consequences of false memories for food preferences and choices. Perspectives on Psychological Science, 4, 135-139. Peterson, T., Kaasa, S.,O. & Loftus, E.F. (2009). Me too! : Social Modeling Influences on Early Autobiographical Memories. Applied Cognitive Psychology. 23,

States Attorneys - Of Counsel - EFTA00093262 Cassel.20-Z74030ASNII Mai OM& WV 1FMSZEZ9B3/20gell gyec2

in to French authorities in Guadeloupe and confessed to committing a murder in the United States. Despite turning himself in to French authorities, Peterson remained beyond the reach of U.S. law enforcement despite the repeated requests of OIA and U.S. officials. See Durbin, Schakowsky, Emanuel (bye Fre