Epstein Secrets

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 Hac 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

ntiff in Related Case No. 08- 80893, - • Paul G. Cassell, Esq. Pro Hac Vice 332 South 1400 E, Room 101

al as that information is within the penumbra of the protections of Federal Rules of Evidence 408 and 410. Moreover, despite Plaintiffs contention, Federal Rule of Evidence 410 is applicable because negotiations did not end with a federal plea. Furthermore, Federal Rule of Evidence 408 is applicable given that 18 U.S.C. 22

REPLY IN SUPPORT OF MOTION TO DISMISS NON-PARTY INTERLOCUTORY APPEAL Bradley J. Edwards FARMER, JAFFEE, WEISSING EDWARDS, FISTOS & LEHRMAN, P.L. Paul G. Cassell Attorneys for Plaintiffs-Appellees Jane Doe No.1 and Jane Doe No. 2 EFTA00209494 TABLE OF CONTENTS INTRODUCTION 1 I. THIS COURT SHOULD IMMEDIA

EISSING EDWARDS, FISTOS & LEHRMAN, P.L. Paul G. Cassell Attorneys for Plaintiffs-Appellees Jane Doe No.1

specifically noted this evidentiary problem with Epstein's claim. The District Court gave as one reason for rejecting Epstein's contention based on Federal Rule of Evidence 410 that the rule does not even possibly protect "general discussions of leniency and statements made in the hope of avoiding a federal indictment - ar

good transcending the normally predominant prin- ciple of utilizing all rational means for ascertaining truth. Fed.Rules Evid.Rule 501, 28 U.S.C.A. Paul Cassell, University of Utah College of Law, Salt Lake Cty, UT, Bradley James Edwards, Farmer Jaffe Weissing Edwards Fistos & Lehman, PL, Fort Lauderdale, FL

ruth. Fed.Rules Evid.Rule 501, 28 U.S.C.A. Paul Cassell, University of Utah College of Law, Salt Lake Cty

P. 24(b), the intervenors moved for protective orders. The intervenors argued that the work-product priv- ilege protects their correspondence; that Federal Rule of Evidence 410 and Feder- al Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jur

my Crime Victims' Rights Act... Page 1 of 3 Print Eleventh Circuit rules that discovery can move forward on my Crime Victims' Rights Act case By Paul Cassell Updated: April 21 at 9:41 am On Friday the 1 1 th Circuit ruled that discovery can move forward in an important Crime Victims' Rights Act case that

sentence. in a vacant wing of the Palm Beach County Stockade, and was lel out on work release six days a week for up to 16 hours a day. Edwards and Cassell represent Jane Doe No. 1 and Jane Doe No. 2, who say the U.S. Attorney's Office violated the Crime Victims' Rights Act by signing the federal non-pr

discovery of the correspondence between the U.S. and 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, barring release of the correspondence. They also argued that th

2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: [email protected] and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah6 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile:

075 E-mail: [email protected] and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the

against him because of Rule 410 of the Federal Rules of Evidence. See Exhibit A to Epstein's Mot. to Intervene, DE #93-1 (arguing that pursuant to Federal Rule of Evidence 410, Epstein is entitled to some sort of protective order). If this pleading has a familiar ring to it, it is because Epstein has presented it to this

, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale. 1 Telepho Facsimil Florida Bar No.: 542075 E-mail: and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah° 332 S. 1400 E. Salt Lake • Telephone Facsimile: E-Mai Attorneys for Jane

l Florida Bar No.: 542075 E-mail: and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the

against him because of Rule 410 of the Federal Rules of Evidence. See Exhibit A to Epstein's Mot. to Intervene, DE #93-1 (arguing that pursuant to Federal Rule of Evidence 410, Epstein is entitled to some sort of protective order). If this pleading has a familiar ring to it, it is because Epstein has presented it to this

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

r discovery of the correspondence between the U.S. and 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, barring release of the correspondence. They also argued that the

"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

ane Doc 2 to release materials that are plainly the privileged opinion work-product of the attorneys, that constitute settlement negotiations under Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure II, and that contain information about matters occurring before the grand jury, which arc strictly confidenti

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

r discovery of the correspondence between the M. and Epstein's attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure I I create a privilege for plea negotiations, barring release of the correspondence. They also argued that t

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

y of the correspondence between the 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