5
Shared Docs
5
Same-Page
10 / 5
Mentions
ru Southern District of Florida, seeking advice P-013278 regarding office-wide recusal, dated December 16 and 17, 2010, with attached letter from Paul Cassell to Wifredo A. Ferrer, dated December 10, 2010 Page 23 of 23 EFTA00086444 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 P
ted States, Case No. 08-80736-C1V-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Fort Lauderdale FL 33301-3268 Fax: Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Ci Utah 84112 Fax: (801) 585-6833 E-mail: Attorneys for Jane D
ida Fort Lauderdale FL 33301-3268 Fax: Paul G. Cassell S.J. Quinney College of Law at the University o
r, and subject to any other conditions that it directs — of a grand-jury matter: (i) preliminarily to or in connection with a judicial proceeding." Federal Rule of Criminal Procedure 6(e) provides that the traditional rule of grand jury secrecy may be placed aside under certain circumstances to allow for disclosure. S
, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 Attorneys f
301 (954) 524-2820 Fax: (954) 524-2822 Paul G. Cassell S.J. Quinney College of Law at the University o
vernment." See supra at 1-3. The Respondent also objects to Requests No. 26(a)-26(e) as calling for responses that are protected from disclosure by Federal Rule of Criminal Procedure 6(e), by the law enforcement investigative privilege, and by the work product doctrine. Notwithstanding the foregoing objection, the Resp
"civil" case. 6 EFTA00177110 Case 9:08-cv-80736-KAM Document 49 Entered on FLSD Docket 03/21/2011 Page 7 of 10 Letter from Wifredo A. Ferrer to Paul G. Cassell (March 15, 2011).3 Accordingly, the victims were left with no choice but to file a motion without stipulated facts. Contemporaneously with the filin
f the proposed "undisputed material facts" arc in fact disputed and, in many cases, wrong. 'The 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
ssemination of these letters because they contain information from the grand jury's investigation, and this information is confidential pursuant to Federal Rule of Criminal Procedure 6(e). In an abundance of caution, defense team members Roy Black and Martin Weinberg, two of the attorneys who represented Jeffrey Epstei
h Circuit Court on April 18 2014, ruled In favor of two crime victims represented by Farmer Jaffe WelteJng Partner Brad Edwards and his co-counsel. Paul Cassell F0 watt:aft litter...se PRCoy (PresTReleiso)• Apr. 22, 2014 • FORT LAUDERDALE, FM. - Contact Brad Edwards. Farmer. Jails Weissing. Edwards. Philo
mmen! that resulted In the goiemmant electing not to Federally prosecute Epstein lor his many sexual crimes against children. Attorneys Edwards and Cassell argued the case bolero the Elmonlh Circuit in February. against attorneys Roy Black and Marlin Weinberg The case in oleos a federal criminal in ati
he United States are Epstein's attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations blocking release of the correspondence. They also argued that the cowl should find that the m
iscovery and admissibility as is set forth in the incorporated memorandum. Mr ;LETS DISCUSS - DOES THIS BROADEN THE INTERVENTION - WHAT EXACTLY HAS CASSELL ASKED FOR] Epstein also objects to any further , as-well-as-dieir-Footien-te disseminate the plea negotiation &communications or its content -to th
orandum of law. Part I shows that the Court should deny disclosure and use of the plea negotiations by simple reference to Rule of Evidence 410 and Federal Rule of Criminal Procedure 11(0, without having to reach the other issues raised by the parties and the proposed intervenors. This is because during the hearing on
Entities connected to both Paul Cassell and Federal Rule of Criminal

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONJack Goldberger
PERSON
Salt Lake City
LOCATIONMaria Farmer
PERSONRobert D. Critton
PERSONSouthern District
LOCATIONMichael J. Pike
PERSON
Adam D. Horowitz
PERSON
United States
LOCATION
the University of Utah
ORGANIZATIONLeon Black
PERSON
Scarlett Johansson
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATIONJack Scarola
PERSON
S.J. Quinney College of Law
ORGANIZATION