Epstein Secrets

Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. Fort Lauderdale, Florida 33301 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Salt Lake City, UT 84112 Attorneys for Jane Doe #1 and Jane Doe #2 26 EFTA0

.L. Fort Lauderdale, Florida 33301 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the

ot such course of conduct and, in any event, the victims have never "accepted" that the correspondence is protected. Moreover, in an effort to show the Courts of Appeals are inconsistent, the Government pretends to have universally surveyed caselaw with its citations to just these two allegedly "inconsistent" cases.

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

sive, piecemeal appeals of all adverse attorney-client rulings would unduly delay the resolution of district court litigation and needlessly burden the Courts of Appeals" (emphasis added)). In holding that an interlocutory appeal would not lie, the Mohawk Court concluded that postjudgment appeals generally suffice t

ictims Fairly: Integrating Victims into the Federal Rules o Criminal Procedure 2007 Reporter 2007 Utah L. Rev. 861 * Length: 59852 words Author: Paul G. Cassell* * Professor of Law, S.J. Quinney College of Law of the University of Utah, Judge, U.S. District Court for the District of Utah, 2002-07. Thanks to

in the Federal Rules of Criminal Procedure: Proposed Amendments in Light of the Crime Victims’ Rights Act, 2005 BYU L. Rev. 835, 852-924 [hereinafter Cassell, Proposed Amendments]. 5 18 U.S.C. § 3771 (a)(8). DAVID SCHOEN HOUSE_OVERSIGHT_017637 --- PAGE BREAK --- Page 3 of 78 2007 Utah L. Rev. 861, *865

also the fact that the victim has an objection to the plea. In deciding whether to accept a plea, the court must consider the public interest. '4 As the Courts of Appeals have explained, ""Rule 11 also contemplates the rejection of a negotiated plea when the district court believes that bargain is too lenient, or other