Epstein Secrets

e it would be in the Government's EFTA00209340 interest to endorse. Sincerely, Brad Edwards and Paul Cassell for lane Doe ttl. and Jane Doe tt2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Quinney College of Law at the University of Utah 332 South 1400 East, Room 101 Salt Lake Ci

If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the bars of other states. Thank you. From: Paul Cassell Sent: Thursda , June 27, 2013 7:16 AM To: ,

electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the b

of DOD's position on interlocutory appeals is that they are notimnissible in these circumstances, particularly in light of Mohawk Industries, Inc. I Carpenter, 130 =. 599 (2009) (affirming 11th Circuit decision that an attorney-client rivilege order is not immediately appealable). As you probably know, E

n on the motion. Please let us know when it would be convenient to confer. Sincerely, Brad Edwards and Paul Cassell for Jane Doe #1 and Jane Doe #2 Paul G. Cassell Subject: RE: Are you going to confer with us? It has been nearly two weeks since we sent this request to you, and we haven't heard anything back fr

e #2 Paul G. Cassell EFTA00209563 error, please immediately notify the sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the bars of other states. Thank you. From: Paul Cassell Sent: Monday, June 24, 2013 6:46 PM Subject: R

electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the b

DOD's position on interlocutory appeals is that they are not permissible in these circumstances, particularly in light of Mohawk Industries, Inc. I Carpenter, 130 S.C.t. 599 (2009) (affirming 11th Circuit decision that an attorney-client rivilege order is not immediately appealable). As you probably know

AFFEE, WEISSING EDWARDS, FISTOS & LEHRMAN, P.L. 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]

hat the following persons have an interest in the outcome of this case: 1. Marra, The Honorable Kenneth 2. Acosta, R. Alexander 3. Black, Roy 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo A. 8. Howell, Jay 9. 10. 11. 12. 13. 14. 15. l• 16. Weinberg, Mar

C. Cir. 2013) 13, 17 Miccosukee Tribe of Indians of Florida v. United States, 516 F.3d 1235, 1265 (11th Cir. 2008) 21 Mohawk Industries, Inc. v. Carpenter, 130 S. Ct. 599 (2009) passim Nat'l Super Spuds, Inc. v. N.Y. Mercantile Exch., 591 F.2d 174, 178 (2d Cir.1979) 13 Perlman v. United States, 24

AFFEE, WEISSING EDWARDS, FISTOS & LEHRMAN, P.L. 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]

(954) 524-2820 [email protected] Paul G. Cassell S. J. Quinney College of Law at the University

n to dismiss for lack of jurisdiction, explaining that this Court did not have jurisdiction to review the discovery order under Mohawk Industries I Carpenter, 558 U.S. 100 (2009). On July 12, 2013, Epstein responded in opposition to the motion to dismiss, and on July 16, 2013, the victim's replied in sup

REPLY IN SUPPORT OF MOTION TO DISMISS NON-PARTY INTERLOCUTORY APPEAL Bradley J. Edwards FARMER, JAFFEE, WEISSING EDWARDS, FISTOS & LEHRMAN, P.L. Paul G. Cassell Attorneys for Plaintiffs-Appellees Jane Doe No.1 and Jane Doe No. 2 EFTA00209494 TABLE OF CONTENTS INTRODUCTION 1 I. THIS COURT SHOULD IMMEDIA

EISSING EDWARDS, FISTOS & LEHRMAN, P.L. Paul G. Cassell Attorneys for Plaintiffs-Appellees Jane Doe No.1

, that this Court lacks jurisdiction over such an interlocutory appeal in light of the Supreme Court's recent decision in Mohawk Industries, Inc.'. Carpenter, 130 S. Ct. 599 (2009) (attorney-client privilege ruling not immediately appealable; any injury can be addressed at conclusion of case) (Mot. Dismis

Appellants OPPOSITION TO MOTION FOR STAY OF DISTRICT COURT DISCOVERY ORDER PENDING APPEAL AND REQUEST FOR AN EXPEDITED RULING Bradley J. Edwards Paul G. Cassell FARMER, JAFFEE, WEISSING S. J. Quinney College of Law at EDWARDS, FISTOS & LEHRMAN, P.L. the University of Utah Attorneys for Plaintiffs-Appelle

AN EXPEDITED RULING Bradley J. Edwards Paul G. Cassell FARMER, JAFFEE, WEISSING S. J. Quinney College

motion to dismiss Epstein's interlocutory appeal, explaining that this Court lacked 6 EFTA00209513 jurisdiction in light of Mohawk Industries'. Carpenter, 558 U.S. 100 (2009). On June 26, 2013, Epstein sought a stay of the district court pending appeal. DE 193. Two days later, the victims opposed the

13 Page 15 of 16 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe #1 and Jane Doe #2 15 EFTA00209614 Case 9:08-cv-807

G, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the

matic example of when interlocutory appeals are proper, the Supreme Court has recently and flatly concluded otherwise. In Mohawk Industries, Inc. I Carpenter, 130 S.Ct. 599 (2009), an opinion that immediately appears when performing basic research on this issue, the Supreme Court affirmed the Eleventh Ci

hat the following persons have an interest in the outcome of this case: 1. Marra, The Honorable Kenneth 2. Acosta, R. Alexander 3. Black, Roy 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo A. 8. Howell, Jay 9. 10 11 12 13 14 15 11 Page C-1 of 2 EFTA00209

Appx. 286 (4th Cir. 2012), cert. denied, 133 S.Ct. 991 (2013) 55 *Missouri v. Frye, 132 S. Ct. 1399 (2012) 12, 35,36 Mohawk Industries, Inc. v. Carpenter, 558 U.S. 100 (2009) 46, 47, 48, 49, 51 EFTA00209664 Case: 13-12923 Date Filed: 08/05/2013 Page: 9 of 75 Moulder v. State, 154 Ind. App. 248,

d-class faculty has included Darol Anger, Hanneke Cassel, Joe Craven, Rushad Eggleston, Brittany Haas, Nat

ociation, Measure for Measure, which was presented in Gallery 825 in Los Angeles, at the Guggenheim Gallery at Chapman University, and at Harvard’s Carpenter Center. In 2012, she was the recipient of the Andrew Gemant Award from the American Institute of Physics, which is given annually for significant co