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e #2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 [email protected] Counsel for Plaintiff in Related Case No. 08-80893 Paul G. Cassell, Esq. Pro Hae Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] 8 Case 9:08-cv-8
Plaintiff in Related Case No. 08-80893 Paul G. Cassell, Esq. Pro Hae Vice 332 South 1400 E, Room 101
2 F.R.D. 685 (S.D. Fla. 2007). See Hickman v. Taylor, 329 U.S. 495, 507-08 (1947); Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 351 (1978). In Oppenheimer, the Supreme Court discussed the concept of relevance in relation to Fed. R. Civ. P. 26(b) and noted that: The key phrase in this definition - "rel
[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
ar on any issue that is or may be in the case.” Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978).
t.com Michael James Pike [email protected] Paul G. Cassell [email protected] Richard Horace Willits
[email protected] and Paul G. Cassell Pro Hac Vice 332 S
ar on any issue that is or may be in the case.” Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978).
& Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686-6300 Fax: 561-383-9424 [email protected] [email protected] Paul G. Cassell, Esq. Pro Hae Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plai
24 [email protected] [email protected] Paul G. Cassell, Esq. Pro Hae Vice 332 South 1400 E, Room 101
Motion to Identify. See also Fed.R.Civ.Pro. 26; Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978);
rcy Denney Scarola Barnhart & Shipley, P.A. F Brad Edwards, Esq. Rothstein Rosenfeldt Adler Counsel for Plaintiff in Related Case No. 08-80893 Paul G. Cassell, Esq. Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. Counsel for Plaintiff in Related Case No. 08-80469 Robert
Plaintiff in Related Case No. 08-80893 Paul G. Cassell, Esq. Co-counsel for Plaintiff Jane Doe Isidro
Motion to Identify. See also Fed.R.Civ.Pro. 26; Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978);
e our "summary judgment" pleadings (which we provided in their entirety to your Office as a courtesy six months ago) on March 18, 2011. Sincerely, Paul &Cassell Co-Counsel for Jane Doe #1 and Jane Doe #2 Cc: Special Agent in Charge Miami FBI Field Office 16320 NW 2nd Avenue. North Miami Beach, FL 33169
99 N.E.4th Street Miami, FL 33132 • • PAUL. G. CASSELL Ronald N. Boyce Presidential Professor of Crimin
rum, From Beirut to Kabul, and a segment for The Oppenheimer Report. She is a contributor to The Huffington Po
roceedings, we will be able to prove that clear violation of the CVRA and then obtain the remedy of invalidating the illegally-negotiated plea deal. Paul G. Cassell teaches criminal law, criminal procedure, and crime victims’ rights at the S.J. Quinney College of Law at the University of Utah. Before coming to Ut
at the case will ultimately set an important precedent that federal prosecutors can't keep victims in the dark about the plea deals that they reach." Cassell said. Epstein served 13 months of an 18-month sentence on the prostitution charge. sold his Palm Beach home in 2011 and now divides his time between
orum, From Beirut to Kabul, and a segment for The Oppenheimer Report . She is writing a book about child traffi
when the U.S. Attorney’s Office failed to confer with them before signing a non-prosecution agreement in September 2007. Attorneys Brad Edwards and Paul Cassell, representing Jane Doe No. 1 and Jane Doe No. 2, argued Friday in federal court in West Palm Beach that the governmeni’s action violated the girls’ r
in federal court in West Palm Beach that the governmeni’s action violated the girls’ rights under the federal Crime Victims’ Rights Act. Edwards and Cassell want the agreement nullified and want Marra to unseal un-redacted plea deal correspondence between the U.S. Attorney's Office and Epstein’s defense t
orum, From Beirut to Kabul, and a segment for The Oppenheimer Report. She is a contributor to The Huffington Po
ceedings. we will be able to prove that clear violation of the CVRA and then obtain the remedy of invalidating the illegally-negotiated plea deal. Paul G. Cassell teaches criminal law, criminal procedure. and crime victims' rights at the.. Quinney College of Law at the University of Utah. Before coming to Utah
at the case will ultimately set an important precedent that federal prosecutors can't keep victims in the dark about the plea deals that they reach? Cassell said. Epstein served 13 months of an 18-month sentence on the prostitution charge. sold his Palm Beach home in 2011 and now divides his time betwee
rum. From Beirut to Kabul. and a segment for The Oppenheimer Report . She is writing a book about child traff
rming, erudite, humorous,” one of Seckel’s marks told the reporter. “I lent him $75,000. When the time came to pay it back he didn’t want to do it.” Oppenheimer found several people whom Seckel had stiffed and uncovered dozens of lawsuits he’d been involved in. In 2007, Seckel settled a libel lawsuit against
Page: HOUSE_OVERSIGHT_022131 →s. aves of the ocean. : ymantic, generous gestures that Jee o ‘A . q number of these transactions resulted in accusations and aw Ui ” . . 4 ts," Oppenheimer would write. “In speaking to former HOUSE_OVERSIGHT_022130 --- PAGE BREAK --- JAMES PATTERSON Seckel acquaintances, I kept hearing variations on
Page: HOUSE_OVERSIGHT_022131 →She’s made the whole story up out of whole cloth.” are part of a plot to exto Bradley Edwards had already become involved in lawsuits q Edwards and Cassell have { against Epstein. In 2007, working with a former federal judge i. he’s ever seen. and University of Utah law professor named Paul Cassell, he h
Page: HOUSE_OVERSIGHT_022139 →dan to get off scot-free. But the plot twist that E on the day of Alan Dershow Florida, courthouse was eve “There was a criminal extort Edwards and Paul Cassell’s | 2015. “Your clients were involv Bradley and Cassell had s for defamation— payback fo : law professor had made in th Dershowitz had counters HOUS
Page: HOUSE_OVERSIGHT_022148 →Entities connected to both Paul Cassell and J. Robert Oppenheimer

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Salt Lake City
LOCATIONMaria Farmer
PERSONSouthern District
LOCATIONLeon Black
PERSON
George W. Bush
PERSONRobert D. Critton
PERSON
Prince Andrew
PERSONMichael J. Pike
PERSON
United States
LOCATION
Adam D. Horowitz
PERSONMartin Weinberg
PERSON
the University of Utah
ORGANIZATIONRichard Horace Willits
PERSONJack Patrick Hill
PERSON