Epstein Secrets

ney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. , a

cooperate, cooperation does not mean agreeing to facts that are not relevant to the resolution of the legal dispute at issue .... _ Letter from to Paul G. Cassell (March 15, 2011). 17. Accordingly, unable to work with the Government to reach a resolution of the facts, on March 21, 2011, the victims filed a Mo

U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. , asking him to personally investigate what happened during the Epstein prosecution and how the victim

Entered on FLSD Docket 08/16/2013 Page 43 of 64 with you to try and minimize any unnecessary burden from your discovery obligations. E-mail from Paul G. Cassell & Bradley J. Edwards to , et al., Counsel for the Government (February 25, 2013). The Government ignored the e-mail and did not respond in any way.

il to meet this requirement. 63. A good illustration of the inadequacies of the privilege log comes from the very first entry in the log, covering Box No. 1 (P-000001 through P-000039), some 39 pages of documents. DE 212-1. Yet the only description of these 39 pages is: "File folder entitled 'CORR RE G

cooperate, cooperation does not mean agreeing to facts that are not relevant to the resolution of the legal dispute at issue .... Letter from w to Paul G. Cassell (March 15, 2011). 17. Accordingly, unable to work with the Government to reach a resolution of the facts, on March 21, 2011, the victims filed a Mo

U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. Ferrer, asking him to personally investigate what happened during the Epstein prosecution and how the

ney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. Fer

Entered on FLSD Docket 10/20/2014 Page 43 of 64 with you to try and minimize any unnecessary burden from your discovery obligations. E-mail from Paul G. Cassell & Bradley J. Edwards to et al., Counsel for the Government (February 25, 2013). The Government ignored the e-mail and did not respond in any M. Acc

il to meet this requirement. 63. A good illustration of the inadequacies of the privilege log comes from the very first entry in the log, covering Box No. 1 (P-000001 through P-000039), some 39 pages of documents. DE 212-1. Yet the only description of these 39 pages is: "File folder entitled 'CORR RE G

tion does not mean agreeing to facts that are not relevant to the resolution of the legal dispute at issue . . . . Letter from Wifredo A. Ferrer to Paul G. Cassell (March 15, 2011). 17. Accordingly, unable to work with the Government to reach a resolution of the facts, on March 21, 2011, the victims filed a Mo

U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. Ferrer, asking him to personally investigate what happened during the Epstein prosecution and how the

ney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. Fer

Entered on FLSD Docket 08/16/2013 Page 43 of 64 with you to try and minimize any unnecessary burden from your discovery obligations. E-mail from Paul G. Cassell & Bradley J. Edwards to Dexter Lee. et al., Counsel for the Government (February 25, 2013). The Government ignored the e-mail and did not respond in

il to meet this requirement. 63. A good illustration of the inadequacies of the privilege log comes from the very first entry in the log, covering Box No. 1 (P-000001 through P-000039), some 39 pages of documents. DE 212-1. Yet the only description of these 39 pages is: "File folder entitled 'CORR RE G

ooperation does not mean agreeing to facts that are not relevant to the resolution of the legal dispute at issue . . . . Letter from Wifredo A. to Paul G. Cassell (March 15, 2011). 17. Accordingly, unable to work with the Government to reach a resolution of the facts, on March 21, 2011, the victims filed a Mo

ney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. ask

U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. asking him to personally investigate what happened during the Epstein prosecution and how the victims

il to meet this requirement. 63. A good illustration of the inadequacies of the privilege log comes from the very first entry in the log, covering Box No. 1 (P-000001 through P-000039), some 39 pages of documents. DE Si. Yet the only description of these 39 pages is: "File folder entitled 'CORR RE GJ

, cooperation does not mean agreeing to facts that are not relevant to the resolution of the legal dispute at issue .... Letter from Wifredo A. to Paul G. Cassell (March 15, 2011). 17. Accordingly, unable to work with the Government to reach a resolution of the facts, on March 21, 2011, the victims filed a Mo

U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. M , asking him to personally investigate what happened during the Epstein prosecution and how the vict

ney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. M ,

il to meet this requirement. 63. A good illustration of the inadequacies of the privilege log comes from the very first entry in the log, covering Box No. 1 (P-000001 through P-000039), some 39 pages of documents. DE M-1. Yet the only description of these 39 pages is: "File folder entitled 'CORR RE GJ

aims Against Public Prosecutor; Attorney Conduct at Issue Suppl. Box 3 P-013925 Thru P-013927 Draft Letter, from Robin C. Ashton to Professor Paul G. Cassell, with handwritten correction Deliberative Process Privilege Attorney Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; No

075 E-mail: [email protected] and Paul G. Cassell Pro Hac Vice 1 EFTA00179619 Case 9:08-cv-807

en notes." 64. Another good illustration of the inadequacies of the privilege log is provided on page 20 of the first privilege log, with regard to Box No. 3 (P-012362 through P-012451). The Government asserts privilege here regarding 90 pages of documents. Yet the only description of these 90 pages is