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

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s MOTION for Hearing filed by United States of America. (Lee, Dexter) (Entered: 04/08/2011) 04/08/201 1 a 04/08/2011 ...... a ) SYSTEM ENTRY — Docket Entry 63 restricted/scaled until further notice. (dj) (Entered: 04/08/2011) 04/08/2011 6 SYSTEM ENTRY — Docket Entry 64 restricted/sealed until further

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

jury. Pursuant to Fed. R. Crim. P. 6(e), the Government cannot confirm or deny the accuracy of those allegations. Likewise, portions of Exhibit A to Docket Entry 48 refer to matters occurring before the Grand Jury. Notwithstanding Petitioners' citations to the First Amendment and the interest of the press an

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

jury. Pursuant to Fed. R. Crim. P. 6(e), the Government cannot confirm or deny the accuracy of those allegations. Likewise, portions of Exhibit A to Docket Entry 48 refer to matters occurring before the Grand Jury. Notwithstanding Petitioners' citations to the First Amendment and the interest of the press an

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

jury. Pursuant to Fed. R. Crim. P. 6(e), the Government cannot confirm or deny the accuracy of those allegations. Likewise, portions of Exhibit A to Docket Entry 48 refer to matters occurring before the Grand Jury. Notwithstanding Petitioners' citations to the First Amendment and the interest of the press an

"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

jury. Pursuant to Fed. R. Crim. P. 6(c), the Government cannot confirm or deny the accuracy of those allegations. Likewise, portions of Exhibit A to Docket Entry 48 refer to matters occurring before the Grand Jury. Notwithstanding Petitioners' citations to the First Amendment and the interest of the press an

epted should be denied. aOnly Jane Doe #1 and her counsel elected to attend this meeting. L2The U.S. Attorney's Office also repeatedly reminded Mr. Cassell, a former federal judge and Justice Department official, of the Justice Department's policy not to comment on the guilt or innocence of an unconvic

e the trial." Focusing just on the second half of that Rule, for now, as the United States has explained since the very start of the litigation, in Docket Entry No. 19, on August 1, 2008, and as admitted by Petitioners during the hearing on August 14, 2008, no additional facts are needed. The only material f

es, Attached please find my draft opposition to the petitioners' motion for finding of violations of the CVRA. I have responded to the arguments in Cassell's motion, and also argued that the court lacks authority to set aside the non-prosecution agreement, assuming arguendo it found a violation of secti

» One thought on the "statement of undisputed facts," I would not respond to it at all in this response, I would only discuss it in the response to Docket Entry 49 ("Jane Does Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts.") First I would hammer the fact

S); Attached please find my draft opposition to the petitioners' motion for finding of violations of the CVRA. I have responded to the arguments in Cassell's motion, and also argued that the court lacks authority to set aside the non-prosecution agreement, assuming arguendo it found a violation of secti

. One thought on the "statement of undisputed facts," I would not respond to it at all in this response, I would only discuss it in the response to Docket Entry 49 ("Jane Does Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts.") First I would hammer the fact