Epstein Secrets

N OPPOSITION TO DEFENDANT'S MOTIONS TO DISOALIFY PROFESSOR CASSELL AND MR. EDWARDS FROM REPRESENTING MS. by and th

No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF, CONSOLIDATED REPLY IN OPPOSITION TO DEFENDANT'S MOTIONS TO DISOALIFY PROFESSOR CASSELL AND MR. EDWARDS FROM REPRESENTING MS. by and through her undersigned counsel, respectfully submits this Consolidated Reply in Opposition to Defend

ndersigned counsel, respectfully submits this Consolidated Reply in Opposition to Defendant's Letters, Construed as Motions to Disqualify Professor Paul Cassell and Mr. Edwards from Representing Ms. For the reasons set forth below, this Court should deny both of Defendant's Letter Motions, and grant Profes

. United States, 134 S. Ct. 1710 (2014) (arguing before the Supreme Court on behalf of "Amy," a child pornography victim seeking restitution); In re Antrobus, 519 F.3d 1123 (10th Cir. 2008) (arguing for opportunity for victim to deliver a victim impact statement). His previous experience will be valuable

e No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., F E-mail: [email protected] Paul G. Cassell Attorneys for Jane Doe # 1 and Jane Doe # 2 22 EFTA00205623

Esq., F E-mail: [email protected] Paul G. Cassell Attorneys for Jane Doe # 1 and Jane Doe # 2 22

iscuss ... allegations of criminal acts and [DOJ's] decisions to prosecute or not prosecute') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve

Edwards, Esq., Farmer, Jaffe, Weissing, Paul G. Cassell Attorneys for Jane Doe # 1 and Jane Doe # 2 37

tes, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing, Paul G. Cassell Attorneys for Jane Doe # 1 and Jane Doe # 2 37 EFTA00205660

iscuss ... allegations of criminal acts and [DOJ's] decisions to prosecute or not prosecute') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve

Paul G. Cassell, Esq. October 23, 2010 U.S. Attorney's Office for the Southern District of Florida 99 N.E. 46' Street Miami, FL 33131Via Re: Protecting the Ri

Protecting the Rights of Jane Doe #1 and Jane Doe #2 Dear Dexter: First, as mentioned before, please feel free to call me "Siii rather than "Judge Cassell." Brad Edwards and I hope to build a close and friendly working relationship with you as we proceed with our efforts to protect victims' rights. Al

for these courts (including courts of this Circuit). See, e.g., In re Stewart (I Ph Cir. 2008) (CVRA enforcement action commenced by motion); In re Antrobus (10th Circuit 2008) (same); In re Dean (5th Cir. 2008) (same). Indeed, in an important case in the District of Montana involving enforcement of vict

Paul G. Cassell, Esq. Assistant U.S. Attorney U.S. Attorney's Office for the Southern District of Florida Re: Protecting the Rights of Jane Doe #1 and Jane Doe

a Re: Protecting the Rights of Jane Doe #1 and Jane Doe #2 Dear First, as mentioned before, please feel free to call me "Paul" rather than "Judge Cassell." Brad Edwards and I hope to build a close and friendly working relationship with you as we proceed with our efforts to protect victims' rights. Al

for these courts (including courts of this Circuit). See, e.g., In re Stewart (I Ph Cir. 2008) (CVRA enforcement action commenced by motion); In re Antrobus (10th Circuit 2008) (same); In re Dean (5th Cir. 2008) (same). Indeed, in an important case in the District of Montana involving enforcement of vict

about how the government should handle every aspect of this matter, both in civil and potential criminal proceedings." Letter from Byung J. Pak to Paul G. Cassell (May 7, 2019), attached as Exhibit 1. This invitation remains open. The government's efforts to speak with victims are ongoing, and it will seek le

roceedings." Letter from Byung J. Pak to Paul G. Cassell (May 7, 2019), attached as Exhibit 1. This invita

cuss ... allegations of criminal acts and [DOJ's] decisions to prosecute or not prosecute"') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve

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-mai . eas

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

scuss ... allegations of criminal acts and [DDT's] decisions to prosecute or not prosecute"') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve

/JOHNSON United States District Court, Southern District of Florida Brad 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 36 EFTA00795206 Case 9:08-cv-80736-KAM Docum

issing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the University o

scuss ... allegations of criminal acts and [DDT's] decisions to prosecute or not prosecute"') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve

hrman, 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-mat . cas

24-2822 E-mail: [email protected] Paul G. Cassell S.J. Quinney College of Law at the University o

scuss ... allegations of criminal acts and [DOJ's] decisions to prosecute or not prosecute"') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve

, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fax: E-mail: Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Cit Utah 84112 Fax: Attorneys for Jane Doe # 1 and Jane Doe # 2

Lauderdale, Florida 33301 Fax: E-mail: Paul G. Cassell S.J. Quinney College of Law at the University o

scuss ... allegations of criminal acts and [DDT's] decisions to prosecute or not prosecute"') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve