6
Shared Docs
6
Same-Page
12 / 6
Mentions
that a plea agreement had already been reached. Professor Cassell has spoken to Meg Garvin, Esq., at the National
you back my proposed stipulated facts. I. I am working with two other attorneys on this case — Jay Howell in Jacksonville, Florida. and Professor Paul Cassell in Salt Lake City, Utah. Because they were not in court for the hearing last Friday, they will need to review a transcript of the hearing before our
ention the federal non-prosecution agreement to this counsel and that you did not mention that a plea agreement had already been reached. Professor Cassell has spoken to Meg Garvin, Esq., at the National Crime Victims' Law Institute, and that is her recollection of the events. 7. I think that your pro
tein)). Congress intended the CVRA to dramatically rework the federal criminal justice system. In the course of construing the CVRA generously, the Ninth Circuit observed: "The criminal justice system has long functioned on the assumption that crime victims should behave like good Victorian children -- seen b
2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 [email protected] 5 Counsel for Plaintiff in Related Case No. 08- 80893 Paul G. Cassell, Esq. ProHac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plain
Plaintiff in Related Case No. 08- 80893 Paul G. Cassell, Esq. ProHac Vice 332 South 1400 E, Room 101 S
for their contention that "[a]dditional in camera submissions should not be allowed on appeal." See Response (DE #525) at 2. Instead, they cite the Ninth Circuit Howell case, which held that a Court has discretion to reject newly offered evidence in an appeal of a magistrate judge's decision. Plaintiffs advan
[email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike [email protected] Paul G. Cassell [email protected] Richard Horace Willits [email protected] Robert C. Josefsberg [email protected] Case 9:08-cv-80119-KAM
thtojustice.com and Paul G. Cassell Pro Hac Vice 332 S
ment clearly has prior knowledge of documents that it gave to Epstein. Here, then – as the magistrate judge properly held relying on an instructive Ninth Circuit opinion (not discussed by Epstein) -- the “existence and location of the documents . . . are a ‘foregone conclusion’ and [Epstein] . . . adds littl
STOS & LEHRMAN, P.L. Bradley J. Edwards Paul G. Cassell S.J. Quinney College of Law at the University o
they could bring their concerns to your attention. Very truly yours, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Bradley J. Edwards Paul G. Cassell S.J. Quinney College of Law at the University of Utah• BJE: mwk Enclosures This daytime business address is provided for identification and corre
tein)). Congress intended the CVRA to dramatically rework the federal criminal justice system. In the course of construing the CVRA generously, the Ninth Circuit observed: "The criminal justice system has long functioned on the assumption that crime victims should behave like good Victorian children -- seen b
lorida 33020 Telephone: Facsimile: E-Mail: 6 EFTA00180697 Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 7 of 8 Paul G. Cassell Attorney for Petitioners Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: Facsimile: E-Mall: Jay C. Howell, Esquire Attorney
d on FLSD Docket 09/25/2008 Page 7 of 8 Paul G. Cassell Attorney for Petitioners Pro Hac Vice 332 S. 1
tein)). Congress intended the CVRA to dramatically rework the federal criminal justice system. In the course of construing the CVRA generously, the Ninth Circuit observed: "The criminal justice system has long functioned on the assumption that crime victims should behave like good Victorian children -- seen b
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
e Fourth Circuit found jurisdiction based on Perlman in a civil case, Mezu v. Morgan State University, 495 Fed. Appx. 286, 289 (4th Cir. 2012); the Ninth Circuit has applied Perlman in a case arising under 28 U.S.C. §2255, United States v. Gonzalez, 669 F.3d 974, 977 n.2 (9th Cir. 2012), and in a civil case,
Entities connected to both Paul Cassell and Ninth Circuit

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONJack Goldberger
PERSON
Salt Lake City
LOCATIONMaria Farmer
PERSONRobert D. Critton
PERSONMichael J. Pike
PERSONSouthern District
LOCATION
Adam D. Horowitz
PERSON
Scarlett Johansson
PERSONLeon Black
PERSON
United States
LOCATIONKatherine W. Ezell
PERSONthe Southern District
LOCATION
Ghislaine Maxwell
PERSON
Prince Andrew
PERSONRobert C. Josefsberg
PERSON