Epstein Secrets

ATED: March 21.2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS. FIST LEHRMAN. P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe #1 and Jane Doe #2 40 EFTA00235790 CERTIFICATE OF S

SING, EDWARDS. FIST LEHRMAN. P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the

is no way of knowing whether the State would have offered a plea bargain within the proper range of punishment that he deemed acceptable"); State.. Mazzone, W.Va. 368, 572 S.E.2d 891, 897 (2002) (where plea agreement was that defendant would plead guilty to 2 felony counts of felon in possession of fi

about how the government should handle every aspect of this matter, both in civil and potential criminal proceedings." Letter from Byung J. Pak to Paul G. Cassell (May 7, 2019), attached as Exhibit 1. This invitation remains open. The government's efforts to speak with victims are ongoing, and it will seek le

roceedings." Letter from Byung J. Pak to Paul G. Cassell (May 7, 2019), attached as Exhibit 1. This invita

l plea agreement); State v. Wall, 502 S.E.2d 585, 588 (N.C. 1998) (same); Ex parte Rich,194 S.W.3d 508, 515 (Tex. Crim. App. 2006) (same); State v. Mazzone, 572 S.E.2d 891, 897 (W.Va. 2002) ("[A] plea agreement which cannot be fulfilled based upon legal impossibility must be vacated in its entirety.").

Edwards Edwards Pottinger LP 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone : (800) 400-1098 E-Mail: [email protected] Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah* 383 S. University St. Salt Lake City, UT 84112 Telephone: (801) 585-5202 E-

: (800) 400-1098 E-Mail: [email protected] Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the

tive one); Ex parte Rich, 194 S.W.3d 508, 515 (Tex. Crim. App. 2006) (court cannot enforce an illegal sentence below the statutory range); State v. Mazzone, 212 W.Va. 368, 374 (2002) (court would not enforce plea agreement that called for court to unlawfully sentence the defendant by treating two misdem

Bradley J. Edwards Edwards Pottin er LP Paul G. Cassell Pro Hac Vice This daytime business address is p

TATES JANE DOE 1 AND JANE DOE 2'S REPLY TO INTERVENOR EPSTEIN'S BRIEF IN OPPOSITION TO PROPOSED REMEDIES Bradley J. Edwards Edwards Pottin er LP Paul G. Cassell Pro Hac Vice This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutio

tive one); Ex parte Rich, 194 S.W.3d 508, 515 (Tex. Crim. App. 2006) (court cannot enforce an illegal sentence below the statutory range); State v. Mazzone, 212 W.Va. 368, 374 (2002) (court would not enforce plea agreement that called for court to unlawfully sentence the defendant by treating two misdem