Epstein Secrets

you in advance for considering this request. I would be happy to provide any other additional information that would be useful to you. Sincerely,a Paul Cassel 4 EFTA00231609 SJ. QUINNEY COLLEGE OF LAW THE UNIVERSITY OF UTAH March 1, 2011 Wifredo A. Ferrer United States Attorney Southern District o

OLLEGE OF LAW , THE UNIVERSITY OF UTAH Wifredo A. Ferrer United States Attorney Southern District of Florida 99 N.E.4th Street Miami, FL 33132 PAUL G. CASSELL Ronald N. Boyce Presidential Professor of Criminal Law Telephone: September 29, 2011 Re: Follow-up on leffre,y Epstein Dear Mr. Ferrer: As you

rida 99 N.E.4th Street Miami, FL 33132 PAUL G. CASSELL Ronald N. Boyce Presidential Professor of Crimin

ting criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and to voluntari

f Florida 99 N.E.4th Street Miami, FL 33132 G. CASSELL Ronald N. Boyce Presidential Profes.f Criminal L

you in advance for considering this request I would be happy to provide any other additional information that would be useful to you. Sincerely, Paul G. Casse cc: Assistant U.S. Attorney cc: Assistant U.S. AttorneyM • I 2 EFTA00232725 SJ.QUINNEY COLLEGE OF LAW THE UNIVERSITY OF UTAH 'Wifredo A.

you in advance for considering this request. I would be happy to provide any other additional information that would be useful to you. Sincerely, Pau Cassel • 4 EFTA00232729 QUINNEY COLLEGE OF LAW THE UNIVERSITY OF UTAH March 1, 2011 Wifredo A. Ferrer United States Attorney Southern District of

ting criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and to voluntari

LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, ■. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. el.I.LULLICyJ LU1 J CMG LUC tuna Janc A-ivy Jacqueline Percz

Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the

l her as a prosecution witness, the government would have been obligated to disclose her prior exculpatory statements as impeachment material under Giglio v. United States, 405 U.S. 150 (1972). While petitioners attempt to rehabilitate Jane Doe 2 by relying upon theories of victimization, to explain h

P.L. 425 North Andrews Avenue, Suite 2 Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the

/2017 Page 32 of 33 SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 Attorneys for Jane Doe 1 and Jane

l her as a prosecution witness, the government would have been obligated to disclose her prior exculpatory statements as impeachment material under Giglio v. United States, 405 U.S. 150 (1972). While petitioners attempt to rehabilitate Jane Doe 2 by relying upon theories of victimization, to explain h

S.J. QUINNEY COLLEGE OF LAW THE UNIVERSITY OF UTAH March 1, 2011 Wifredo A. Ferrer United States Attorney Southern District of Florida PAUL G. CASSELL Ronald N. Boyce Presidential Professor of Criminal Law Re: Jane Doe #1 and Jane Doe #2 vs. United States, No. 09-80736 Dear Mr. Ferrer: We are w

s Attorney Southern District of Florida PAUL G. CASSELL Ronald N. Boyce Presidential Professor of Crimin

nting criminals, your 0 ice would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked to voluntarily pr

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

ting criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked Dexter and Marie t

CIV- United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe # 1 and Jane Doe # 2 54 EFTA00230119 Case 9:08-cv-80736-KAM Docum

f the proposed "undisputed material facts" are in fact disputed and, in many cases, wrong. 2The U.S. Attorney's Office also repeatedly reminded Mr. Cassell of the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rule of Professional Conduct

1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment information under Giglio v. United States, 405 U.S. 150 (1972). 2. The parties shall make every possible effort in good faith to stipulate to all facts or points of law th

rman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: bradarloathtoiustice.com Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 841 12 (801) 585-5202 Fax: (801) 585-6833 E-mail: ca

f the proposed "undisputed material facts" are in fact disputed and, in many cases, wrong. 2The U.S. Attorney's Office also repeatedly reminded Mr. Cassell of the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rule of Professional Conduct

1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment information under Giglio i United States, 405 U.S. 150 (1972). 2. The parties shall make every possible effort in good faith to stipulate to all facts or points of law the

: (USAFLS) Sent: Monday, March 21, 2011 9:57 AM To: . (USAFLS) Cc: (USAFLS); (USAFLS) Subject: RE: Planned response to tomorrow's filing by Cassell At the conclusion of the emergency hearing in July 2008, the court asked the parties to meet and decide whether there were any disputed facts, so t

ses all over the country, and he had never had to file a complaint. Now he claims the Federal Rules of Civil Procedure, to say nothing of Brady and Giglio, also apply. From: Sent: Sunda To: Cc: (USAFLS) March 20, 2011 2:40 PM USAFLS (USAFLS); (USAFLS) Subject: Planned response to tomorrow's fi

ffice from Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein prosecution. My guess is it is either Cassell's letter or response thereto. They are going to print tomorrow. From: Sent: To: Cc: Subject: (USAFLS) < Monday, March 21, 2011 9:57 AM (USAF

ses all over the country, and he had never had to file a complaint. Now he claims the Federal Rules of Civil Procedure, to say nothing of Brady and Giglio, also apply. From: Sent: Sunda To: Cc: (USAFLS) March 20, 2011 2:40 PM USAFLS (USAFLS); (USAFLS) Subject: Planned response to tomorrow's fi