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discussed. Moreover, in an effort to facilitate contact on these issues, the same day that filed his motion to intervene (May 3), victims' counsel (Cassell) sent an e-mail to requesting an opportunity to talk with him about his role in the Epstein case. The next day (May 4), sent a letter back refusin
. DATED: May 17, 2011 7 motion to intervene in Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane Doe #2 EFTA00205017 Joseph L. Ackerman, Jr. Fowler White Burnett PA CERTIFICATE OF SERVICE Th
l reluctance of courts to intervene unless requested by one of the parties." Notes of Advisory Committee on Rules-1983 Amendment (emphasis added). New York News, Inc.. Kheel, 972 F.2d 482, 488 (2d Cir. 1992). If motion is allowed to succeed, then legions of bystanders will have the ability to intervene in l
ED: Much 21.2011 Respectfully Submitted, s/ Bradley I. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro MX Vice Quinney College of Law at the University of Utah Attorneys for Jane Due 01 and Jane Doe 02 41 EFTA00229957 Case 9:08-cv-80736-KAM
G, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro MX Vice Quinney College of Law at the Univ
ention. CI Id (permissive intervention denied because it would unduly delay and prejudice imminent settlement of the original claims), aff'd sub nom New York News v. Kheel, 972 F.2d 482, 487 (2d Cir. 1992). Here, the proposed intervention does not create a risk of undue delay or prejudice to the adjudication
ttorneys. 18. Prior to the filing of Plaintiff's Motion for Finding of Violations of the Crime Victims' Rights Act, neither Mr. Edwards, nor Judge Cassell, nor anyone on their behalf contacted me to determine if the allegations in Paragraphs 52 and 53 of that Motion were true. I declare under penalty
62 Entered on FLSD Docket 04/08/2011 Page 49 of 54 draft of Rule 60. See 153 Cong. Rec. 58742, S8746 (June 29, 2007) ("Federal district court judge Paul Cassell initiated the process [of incorporating the CVRA into the Federal Rules] by recommending rule changes to the Advisory Committee on Criminal Rules.")
ntion. CI Id. (permissive intervention denied because it would unduly delay and prejudice imminent settlement of the original claims), aff'd sub nom New York News v. Klieel, 972 F.2d 482, 487 (2d Cir. 1992). Here, the proposed intervention does not create a risk of undue delay or prejudice to the adjudication
Entities connected to both Paul Cassell and New York News

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Kenneth Marra
PERSONMaria Farmer
PERSONLeon Black
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Dexter Lee
PERSONFBI
ORGANIZATIONthe Eleventh Circuit
ORGANIZATIONFlorida Bar
ORGANIZATION
Supreme Court
ORGANIZATION
Fowler
PERSONJoseph L. Ackerman
PERSON
Reinhart
PERSONOffice for the Southern District of Florida
ORGANIZATIONSecond Circuit
ORGANIZATION