Epstein Secrets

Jay Howell &Associates PA 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 Email: [email protected] PRO HAC VICE ATTORNEY TO BE NOTICED Paul G. Cassell Email: PRO HAC VICE ATTORNEY TO BE NOTICED represented by Ann Marie C. Villafana United States Attorney's Office 500 South Australian Ave Suit

nni PRO HAC VICE ATTORNEY TO BE NOTICED Paul G. Cassell Email: PRO HAC VICE ATTORNEY TO BE NOTICED re

to Contest Any of the Facts by Jane Doe. (Edwards, Bradley) (Entered: 03/21/2011) • 03/21/2011 52 Plaintiffs MOTION Jane Doe #1 and Jane Doe #2's Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence by Jane Doe. (Attachments: #1 Exhibit A, #2 Text of Proposed Order PROPOSED ORDER)(Ed

ehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: [email protected] 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 E-mail: cas

524-2822 E-mail: [email protected] Paul G. Cassell S.J. Quinney College of Law at the University o

RELEVANT EVIDENCE Respondent, United States of America, by and through its undersigned counsel, files its Response to Jane Doe #1 and Jane Doe #2's Motion for Order Directing The U.S. Attorney's Office Not to Withhold Relevant Evidence, and states: I. THE CRIME VICTIMS RIGHTS ACT CREATES NO LEGAL DUTY UPON THE U.S. ATT

8/2008) 07/28/2008 16 MOTION for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filing for Paul G. Cassell, Filing Fee $75, Receipt #724532. (cw) (Entered: 07/28/2008) 07/29/2008 17 NOTICE by United States of America To Court Regarding Absence of Need

ay C. Howell Jay Howell & Associates PA Paul G. Cassell En e represented by https://ecf.fisd.circll.den

M/ECF Attorney User's Manual. (Ih) (Entered: 03/23/2011) 03/28/2011 54 NOTICE by Roy Black re 5.Q Plaintiffs MOTION Jane Doe #1 and Jane Doe #2's Motion for Order Directing the US. Attorney's Office Not to Withhold Relevant Evidence, a Plaintiffs MOTION Jane Doe #1 and Jane Doe #2's Motion to Use Correspondence to Prov

O BE NOTICED Farmer Jaffe Weissing Edwards Fistos & Lehrman PL Jav C. Howell PRO HAC VICE;ATTORNEY TO BE NOTICED Jay Howell & Associates PA ISM Paul G. Cassell PRO HAC VICE;ATTORNEY TO BE NOTICED EFTA00211439 Miami , FL 33132 USA 305-961-9320 Fax: 530-7139 Email :[email protected] Roy Black Blac

NOTICED Jay Howell & Associates PA ISM Paul G. Cassell PRO HAC VICE;ATTORNEY TO BE NOTICED EFTA0021143

to Contest Any of the Facts by Jane Doe. (Edwards, Bradley) (Entered: 03/21/2011) 03/21/2011 50 Plaintiff's MOTION Jane Doe #1 and Jane Doe #2's Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence by Jane Doe. (Attachments: # 1 Exhibit A, # 2 Text of Proposed Order PROPOSED ORDER)(E

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

RELEVANT EVIDENCE Respondent, United States of America, by and through its undersigned counsel, files its Response to Jane Doe #1 and Jane Doe #2's Motion for Order Directing The U.S. Attorney's Office Not to Withhold Relevant Evidence, and states: L THE CRIME VICTIMS RIGHTS ACT CREATES NO LEGAL DUTY UPON THE U.S. ATTO

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

RELEVANT EVIDENCE Respondent, United States of America, by and through its undersigned counsel, files its Response to Jane Doe #1 and Jane Doe #2's Motion for Order Directing The U.S. Attorney's Office Not to Withhold Relevant Evidence, and states: L THE CRIME VICTIMS RIGHTS ACT CREATES NO LEGAL DUTY UPON THE U.S. ATTO

"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

RELEVANT EVIDENCE Respondent, United States of America, by and through its undersigned counsel, files its Response to Jane Doc #1 and Jane Doe #2's Motion for Order Directing The U.S. Attorney's Office Not to Withhold Relevant Evidence, and states: I. THE CRIME VICTIMS RIGHTS ACT CREATES NO LEGAL DUTY UPON THE U.S. ATT