Epstein Secrets

ney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. , a

cooperate, cooperation does not mean agreeing to facts that are not relevant to the resolution of the legal dispute at issue .... _ Letter from to Paul G. Cassell (March 15, 2011). 17. Accordingly, unable to work with the Government to reach a resolution of the facts, on March 21, 2011, the victims filed a Mo

U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. , asking him to personally investigate what happened during the Epstein prosecution and how the victim

Entered on FLSD Docket 08/16/2013 Page 43 of 64 with you to try and minimize any unnecessary burden from your discovery obligations. E-mail from Paul G. Cassell & Bradley J. Edwards to , et al., Counsel for the Government (February 25, 2013). The Government ignored the e-mail and did not respond in any way.

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

cooperate, cooperation does not mean agreeing to facts that are not relevant to the resolution of the legal dispute at issue .... Letter from w to Paul G. Cassell (March 15, 2011). 17. Accordingly, unable to work with the Government to reach a resolution of the facts, on March 21, 2011, the victims filed a Mo

U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. Ferrer, asking him to personally investigate what happened during the Epstein prosecution and how the

ney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. Fer

Entered on FLSD Docket 10/20/2014 Page 43 of 64 with you to try and minimize any unnecessary burden from your discovery obligations. E-mail from Paul G. Cassell & Bradley J. Edwards to et al., Counsel for the Government (February 25, 2013). The Government ignored the e-mail and did not respond in any M. Acc

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

tion does not mean agreeing to facts that are not relevant to the resolution of the legal dispute at issue . . . . Letter from Wifredo A. Ferrer to Paul G. Cassell (March 15, 2011). 17. Accordingly, unable to work with the Government to reach a resolution of the facts, on March 21, 2011, the victims filed a Mo

U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. Ferrer, asking him to personally investigate what happened during the Epstein prosecution and how the

ney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. Fer

Entered on FLSD Docket 08/16/2013 Page 43 of 64 with you to try and minimize any unnecessary burden from your discovery obligations. E-mail from Paul G. Cassell & Bradley J. Edwards to Dexter Lee. et al., Counsel for the Government (February 25, 2013). The Government ignored the e-mail and did not respond in

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

ney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. Fer

542075 E-mail: brad(4)pathtojustice.com EFTA00179735 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 38 of 64 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:

U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. Ferrer, asking him to personally investigate what happened during the Epstein prosecution and how the

Entered on FLSD Docket 08/16/2013 Page 43 of 64 with you to try and minimize any unnecessary burden from your discovery obligations. E-mail from Paul G. Cassell & Bradley J. Edwards to Dexter Lee, et al., Counsel for the Government (February 25, 2013). The Government ignored the e-mail and did not respond in

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

ooperation does not mean agreeing to facts that are not relevant to the resolution of the legal dispute at issue . . . . Letter from Wifredo A. to Paul G. Cassell (March 15, 2011). 17. Accordingly, unable to work with the Government to reach a resolution of the facts, on March 21, 2011, the victims filed a Mo

ney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. ask

U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. asking him to personally investigate what happened during the Epstein prosecution and how the victims

ation against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

75 E-mail: brad ®pathtojustice.com and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the

2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad ®pathtojustice.com 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:

Tuite v. Henry, 98 F.3d 1411, 1418 (D.C. Cir. 1996). The balancing is ordinarily made by considering the ten factors identified in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D. Pa. 1973). Those ten factors decisively tip in favor of the victims receiving access to the information. D. Work Product

F on the following: Sigrid S. McCawley Paul G. Cassell Meridith Schultz 383 S. University Street BOIE

TION TO EXTENDING DEADLINE TO COMPLETE DEPOSITIONS AND MOTION FOR SANCTIONS FOR VIOLATION OF RULE 45 via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meridith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 cassel

that witness Rinaldo Rizzo had a deposition re-scheduled from April until June does not have any bearing on the issue presented by this motion. Mr. Rizzo was deposed on June 14 and he has nothing to do with the remaining depositions. Mr. Rizzo, in fact, was practically gleeful to be a witness: Doc.

t Of Motion In Limine To Exclude In Toto Certain Depositions Designated By Plaintiff For Use At Trial via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meredith Schultz 383 S. University Street BOLES, SCHILLER & FLEXNER, LLP Salt Lake it UT 4112 401 East Las Olas Boulevard, Ste. 1200 Ft. Laude

CF on the following: Sigrid S. McCawley Paul G. Cassell Meredith Schultz 383 S. University Street BOLE

trial. She has now obtained an agreement to accept service by Mr. Epstein's counsel, mooting any claim that he is unavailable.' With respect to Mr. Rizzo, she concedes he resides within 100 miles of the courthouse, and provides no basis to claim that he cannot be served. Based on these confessions, th

aims Against Public Prosecutor; Attorney Conduct at Issue Suppl. Box 3 P-013925 Thru P-013927 Draft Letter, from Robin C. Ashton to Professor Paul G. Cassell, with handwritten correction Deliberative Process Privilege Attorney Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; No

075 E-mail: [email protected] and Paul G. Cassell Pro Hac Vice 1 EFTA00179619 Case 9:08-cv-807

Tuite v. Henry, 98 F.3d 1411, 1418 (D.C. Cir. 1996). The balancing is ordinarily made by considering the ten factors identified in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D. Pa. 1973). Those ten factors decisively tip in favor of the victims receiving access to the information. D. Work Product