Epstein Secrets

02/2010 Page 10 of 10 Jane Doe v. Jeffrey Epstein Case No. 08-CIV-80893-MARRA/JOHNSON Epstein's MPO, Objections and Integrated Memo of Law et al. Paul G. Cassell, Esq. Pro Hoc Vice 33 nc_..•L TALMUD IAA uo-umumet for riatnuji Respectfully submitted, /s/ Joseph L Ackerman. Jr. Joseph L Ackerman, Jr. Fl

ctions and Integrated Memo of Law et al. Paul G. Cassell, Esq. Pro Hoc Vice 33 nc_..•L TALMUD IAA uo-

tion. 4. On August 26, 2010, counsel for the Plaintiff served notice of its intent to use the Correspondence in two court proceedings, an internal Justice Department Complaint procedure, and other, essentially public matters. It is also anticipated that the documents will be released to the media. A copy of the Notice of

RDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale. Florida 33301 Telephone Facsimile Florida Bar No.: 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 City. UT 84112 Telephone: Facsimile: E-Mail: Att

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

propriate institution" for the CVRA was the Justice Department, as the Magistrate Judge thought that Jane Doe was proceeding by way of an "internal Justice Department Complaint procedure." Of course, Jane Doe is not proceeding here by way of the internal Justice Department procedure, but rather the statutorily authorized p

: March 21, 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 9 EFTA00208446 Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03)21;2011 Pag

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

propriate institution" for the CVRA was the Justice Department, as the Magistrate Judge thought that Jane Doe was proceeding by way of an "internal Justice Department Complaint procedure." Of course, Jane Doe is not proceeding here by way of the internal Justice Department procedure, but rather the statutorily authorized p

02,2010 Page 10 of 10 Jane Doe v. Jeffrey Epstein Case No. 08-CIV-80893-MARRA/JOHNSON Epstein's MPO, Objections and Integrated Memo of Law et al. Paul G. Cassell, Esq. Pro Hac flee 33 2 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax Casselto(a)law.utakedu Co-Counselfor Pl

ctions and Integrated Memo of Law et al. Paul G. Cassell, Esq. Pro Hac flee 33 2 South 1400 E, Room 101

tion. 4. On August 26, 2010, counsel for the Plaintiff served notice of its intent to use the Correspondence in two court proceedings, an internal Justice Department Complaint procedure, and other, essentially public matters. It is also anticipated that the documents will be released to the media. A copy of the Notice of

blicly accessible records. DATED: March 21, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 9 EFTA00235246 Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 0

. Edwards FARMER, JAFFE, WEISSING, and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the

propriate institution" for the CVRA was the Justice Department, as the Magistrate Judge thought that Jane Doe was proceeding by way of an "internal Justice Department Complaint procedure." Of course, Jane Doe is not proceeding here by way of the internal Justice Department procedure, but rather the statutorily authorized p

02/2010 Page 10 of 10 Jane Doe v. Jeffrey Epstein Case No. 08-CIV-80893-MARRA/JOHNSON Epstein's MPO, Objections and Integrated Memo of Law et al. Paul G. Cassell, Esq. Pro Hac Vice • 33 2 South 1400 E, Room 101 Salt Lake City, UT 84112 Co-Counsel for Plaintiff Respectfully submitted, /s/ Joseph L Ackerm

ctions and Integrated Memo of Law et al. Paul G. Cassell, Esq. Pro Hac Vice • 33 2 South 1400 E, Room 1

tion. 4. On August 26, 2010, counsel for the Plaintiff served notice of its intent to use the Correspondence in two court proceedings, an internal Justice Department Complaint procedure, and other, essentially public matters. It is also anticipated that the documents will be released to the media. A copy of the Notice of

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

propriate institution" for the CVRA was the Justice Department, as the Magistrate Judge thought that Jane Doe was proceeding by way of an "internal Justice Department Complaint procedure." Of course, Jane Doe is not proceeding here by way of the internal Justice Department procedure, but rather the statutorily authorized p

, 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

propriate institution" for the CVRA was the Justice Department, as the Magistrate Judge thought that Jane Doe was proceeding by way of an "internal Justice Department Complaint procedure." Of course, Jane Doe is not proceeding here by way of the internal Justice Department procedure, but rather the statutorily authorized p

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

propriate institution" for the CVRA was the Justice Department, as the Magistrate Judge thought that Jane Doe was proceeding by way of an "internal Justice Department Complaint procedure." Of course, Jane Doe is not proceeding here by way of the internal Justice Department procedure, but rather the statutorily authorized p

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

propriate institution" for the CVRA was the Justice Department, as the Magistrate Judge thought that Jane Doe was proceeding by way of an "internal Justice Department Complaint procedure." Of course, Jane Doe is not proceeding here by way of the internal Justice Department procedure, but rather the statutorily authorized p