Epstein Secrets

course of litigation, unless a court has made a specific finding of misconduct by a DOJ attorney . . . ." Letter from Robin C. Ashton to Professor Paul G. Cassell, May 6, 2001, attached as Exhibit 1 to Victim's Mot. File Supp. Auth. DE #82. Accordingly, an order by this Court making "a specific finding of mis

Letter from Robin C. Ashton to Professor Paul G. Cassell, May 6, 2001, attached as Exhibit 1 to Victim's

es not cite the applicable civil rule is that it has yet to state clearly whether it is willing to abide by the civil rules in this case. See, e.g., Gov't Resp. Mot. Order Not Withhold Evid., DE #59 at 6-7 (refusing to take a position on whether civil rules apply or not). Indeed, the Government has yet to

course of litigation, unless a court has made a specific finding of misconduct by a DOJ attorney . . . ." Letter from Robin C. Ashton to Professor Paul G. Cassell, May 6, 2001, attached as Exhibit 1 to Victim's Mot. File Supp. Auth. DE #82. Accordingly, an order by this Court making "a specific finding of mis

Letter from Robin C. Ashton to Professor Paul G. Cassell, May 6, 2001, attached as Exhibit 1 to Victim's

es not cite the applicable civil rule is that it has yet to state clearly whether it is willing to abide by the civil rules in this case. See, e.g., Gov't Resp. Mot. Order Not Withhold Evid., DE #59 at 6-7 (refusing to take a position on whether civil rules apply or not). Indeed, the Government has yet to

Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. Fort Lauderdale, Florida 33301 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Salt Lake City, UT 84112 Attorneys for Jane Doe #1 and Jane Doe #2 26 EFTA0

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

2). Epstein's lawyers, To be sure, as the Government points out, effective defense counsel should always explore plea bargaining opportunities. See Gov't Resp. at 7 (citing Padilla v. Kentucky, 130 S.C.t 1473, 1485 (2010)). But this is a far cry from proving there is a "right" to plea bargaining or that p

spectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 'ICAtT 1. A • ^I and Paul G. Cassell Pro Hac Vice ir% T el • !I If Attorneys for Jane Doe #1 and Jane Doe #2 8 EFTA00207974 Case 9:08-cv-80736-KAM Document 74 Entered on FLSD

& LEHRMAN, P.L. 'ICAtT 1. A • ^I and Paul G. Cassell Pro Hac Vice ir% T el • !I If Attorneys fo

arding the correspondence, consistent with an earlier order of the magistrate judge. In response, the Government "takes no position" on the motion. Gov't Resp. at 1. Accordingly, this part of the victims' motion should be granted. II. NONE OF THE MATERIALS IN THE CORRESPONDENCE ARE BARRED FROM DISCLOSUR

y J. Edwards FARMER. JAFFE. WLETSSINrk 17 EFTA00208010 Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05/02/2011 Page 28 of 29 and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane Doe #2 28 EFTA00208011 Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05:022011 Pag

LSD Docket 05/02/2011 Page 28 of 29 and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane

gainst Jeffrey Epstein in the U.S. District Court, Southern District of Florida, . . . [the victims] cannot invoke any protections under the CVRA." Gov't Resp. at 8. This sweeping position is simply irreconcilable with § 3771(c)(1) of the CVRA. If an indictment is a prerequisite to CVRA rights, then depar

TED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane Doe #2 conversations with the Government, it has been made clear to victims' counsel that the Gov

G, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane

ernment also cites several cases in which district courts have declined to turn over to crime victims their own confidential pre-sentencing reports. Gov't Resp. at 3-4. These cases about judicial obligations say nothing about prosecutorial obligations under the CVRA "best efforts" provision. It is unsurpri

. On August 14, 2008, a hearing was held, during which a stipulated set of facts was discussed: THE COURT: So if I can hear from Mr. Edwards or Mr. Cassell first what the Plaintiffs' position [is] as far as where we stand on the record in terms of whether I need additional facts, evidence, or there's g

TED: May 2. 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane Doe #2 II EFTA00208034 Case 9:08-cv-80736-KAM Document 75 Entered on FLSD Docket 05)02 2011 Pa

ed by evidence in the record." The Government has briefly recounted a few facts in opposition to a small sliver of the victims' proposed facts. See Gov't Resp. to Victims' Motion to Have Facts Accepted at 11-13. But none of these facts are supported by any evidence at all. The Government should have at le

cember 17. 2015 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. And Paul G. Cassell Pro Hac Vice Attorneys for Jane Does No. 1, 2, 3 and 4 'This daytime business address is provided for identification and correspondence purposes

G, EDWARDS, FISTOS & LEHRMAN, P.L. And Paul G. Cassell Pro Hac Vice Attorneys for Jane Does No. 1, 2,

nt on this point, the Government has contested those requests — even arguing that its FBI agents properly and fully informed the victims. See, e.g., Gov't Resp. to 2d RFA 14(a) (The Government "denies that, during the period from September 24, 2007,through June 2008, the USAO-SDFL did not inform Jane Doe 1

2011) (statement of Sen. Kyl) (quoting his Nov. 2, 2011, letter to Attorney General Holder which, in turn, quotes this Court's decision); see also Paul G. Cassell, Nathanael J. Mitchell & Bradley J. Edwards, Crime Victims' Rights During Criminal Investigations? Applying the Crime Victims' Rights Act Before Cr

quotes this Court's decision); see also Paul G. Cassell, Nathanael J. Mitchell & Bradley J. Edwards, Cri

rnment deny that it sent "victim" notification letters to Jane Doe 2, both before it negotiated the NPA and after. See, e.g., DE 407 at 12,11 93-95 (Gov't Resp. to Victims' Statement of Undisputed Facts) (conceding a victim notification letter was sent to Jane Doe 2 in Jan. 2008). As the Court is well awar

red on FLSD Docket 05/02/2011 Page 28 of 29 EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Cit UT 84112 Attorneys for Jane Doe #1 and Jane Doe

. On August 14, 2008, a hearing was held, during which a stipulated set of facts was discussed: THE COURT: So if I can hear from Mr. Edwards or Mr. Cassell first what the Plaintiffs' position [is] as far as where we stand on the record in terms of whether I need additional facts, evidence, or there's g

against Jeffrey Epstein in the U.S. District Court, Southern District of Florida, . . [the victims] cannot invoke any protections under the CVRA." Gov't Resp. at 8. This sweeping position is simply irreconcilable with § 3771(c)(I) of the CVRA. If an indictment is a prerequisite to CVRA rights, then depar