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STOS & LEHRMAN, P.L. Bradley J. Edwards Paul G. Cassell S.J. Quinney College of Law at the University o
they could bring their concerns to your attention. Very truly yours, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Bradley J. Edwards Paul G. Cassell S.J. Quinney College of Law at the University of Utah• BJE: mwk Enclosures This daytime business address is provided for identification and corre
t the Government to produce all evidence that it possesses supporting these facts, for reasons the victims explain in their contemporaneously-filed Jane Doe NI and Jane Doe #2's Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence. 3 EFTA00210792 Case 9:08-cv-80736-KAM
41 of 42 DATED: March 21. 2011 Respectfully Submitted, pi Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, & LEHRMAN. P.L. and Paul G. Cassell Pro Rae Vice S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe #1 and Jane Doe #2 41 EFTA00208414 Case 9:08-cv-807
, JAFFE, WEISSING, & LEHRMAN. P.L. and Paul G. Cassell Pro Rae Vice S.J. Quinney College of Law at the
at 234-37; Tr. July 11, 2008, 18-19, 22-23, 28- 29? 21. In October 2007, shortly after the initial plea agreement was signed, FBI agents contacted Jane Doe NI. On October 26, 2007, Special Agents and met in person with Jane Doe #1. The Special Agents explained that Epstein would 3 On about August 14, 200
red on FLSD Docket 05/02/2011 Page 28 of 29 EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Cit UT 84112 Attorneys for Jane Doe #1 and Jane Doe
. On August 14, 2008, a hearing was held, during which a stipulated set of facts was discussed: THE COURT: So if I can hear from Mr. Edwards or Mr. Cassell first what the Plaintiffs' position [is] as far as where we stand on the record in terms of whether I need additional facts, evidence, or there's g
EFING SCHEDULE AND HEARING ON THE APPROPRIATE REMEDIES. For all the reasons just explained, the Court should find that the Government has violated Jane Doe NI and Janc Doe #2's rights under the CVRA. At the tail end of its brief, however, the Government briefly raises a flurry of desperate arguments to avo
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
ary 2008 and May 2008. At no time before reaching the non-prosecution agreement did the Justice Department notify any victims, including for example Jane Doe NI, about the non-prosecution agreement. The victims were therefore prevented from exercising their CVRA right to confer with prosecutors about the ca
Jay Howell & Associates PA 644 Cesery Boulevard Suite 250 Jacksonville , FL 32211 Email: [email protected] PRO HAC VICE [Service via CM/ECF] Paul G. Cassell Email: [email protected] [Service via CM/ECF] EFTA00234654 Exhibit 19 EFTA00234655 KIRKLAND & ELLIS LLP AND AMLIATED PARTNIASHIM Jay P.
.com PRO HAC VICE [Service via CM/ECF] Paul G. Cassell Email: [email protected] [Service via CM/EC
tter that contained the language from "Part 3" of the Agreement. Based upon that communication, your Affiant sent the victim notification letter to Jane Doe NI and attached it to your Affiant's July 9,2008 Declaration. 6. Although copies of all of the victim notification letters, including the one addres
Jay Howell & Associates PA 644 Cesery Boulevard Suite 250 Jacksonville , FL 32211 Email: [email protected] PRO HAC VICE [Service via CM/ECF] Paul G. Cassell Email: [email protected] [Service via CM/ECF] EFTA00213132 Exhibit 19 EFTA00213133 KIRKLAND & ELLIS LLP AND AMLIATED PARTNIASHIM Jay P.
.com PRO HAC VICE [Service via CM/ECF] Paul G. Cassell Email: [email protected] [Service via CM/ECF
tter that contained the language from "Part 3" of the Agreement. Based upon that communication, your Affiant sent the victim notification letter to Jane Doe NI and attached it to your Affiant's July 9,2008 Declaration. 6. Although copies of all of the victim notification letters, including the one addres
Entities connected to both Paul Cassell and Jane Doe NI

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONJack Goldberger
PERSONMaria Farmer
PERSONMichael J. Pike
PERSON
the University of Utah
ORGANIZATIONLeon Black
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
S.J. Quinney College of Law
ORGANIZATION
Ghislaine Maxwell
PERSONthe Southern District
LOCATIONRobert C. Josefsberg
PERSON
George W. Bush
PERSONFISTOS & LEHRMAN
ORGANIZATION
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSON