Epstein Secrets

From: Paul Cassell <[email protected]> To: "Lee, Dexter (USAFLS)" <Dexter[email protected]>, Brad Edwards <[email protected]> Cc: "Sanchez, Eduardo (USAFLS)" <[email protected]>, "Villafan

policy, and/or a violation of First Amendment principles. Our filing the entire reply under seal is based upon the November 7, 2011 Order from Judge Middlebrooks, permitting the government to make limited disclosure of Grand Jury matter. Judge Middlebrooks permitted disclosure under three conditions, includi

would fall squarely within the deliberative process privilege. From: Sent: Wednesday, July 03, 2013 12:21 PM To: Sanchez, Eduardo (USAFLS); Lee, Dexter (USAFLS) Subject: RE: Jane Does I United States - Redacted Pleadings Okay. That all sounds good. — Just give me some guidance on how you want me t

n and should nonetheless redact it from the order? I did not do that in the proposed redacted order that I sent you to accompany the motion to Judge Middlebrooks. EFTA00209347 My thought is to prepare one notice of filing to which the 6 separate redacted filings are attached. I'll put one together after lu

ank you for being so accommodating. I know you worked up at Main, so I think you know that all appellate decisions are made by appellate attorneys. Dexter is handling getting an answer and will get back to you as soon as he can. Have a wonderful weekend. I am sure we will talk soon. EFTA00209799 Ass

Normal Yes. I may be overly optimistic, but I expect to have everything done by Monday (Tuesday at the latest), aside from waiting to address Judge Middlebrooks' sealed order. And I expect that we could finalize things fairly quickly after getting the ruling. 10 1111 111 1 uject: : xtensSme re r action I

so accommodating. EFTA00209822 > I know you worked up at Main, so I think you know that all appellate decisions are made by appellate attorneys. Dexter is handling getting an answer and will get back to you as soon as he can. > Have a wonderful weekend. I am sure we will talk soon. > On Jun 28, 201

for a short extension of time to comply with Judge Marra's order requiring us to file unredacted pleadings. Some of those have Judge EFTA00209823 Middlebrooks' sealed order attached and I need to file something with Judge Middlebrooks to avoid getting caught in the crosshairs. I am pretty sure that he is i

55 500 S. Australian Avenue, Suite 400 West Palm Beach, FL 33401 Tel: (561) 820-8711; Fax: (561) 820-8777 Email: [email protected] Dexter A. Lee Assistant United States Attorney Florida Bar No. 0936693 99 N.E. 4th Street Miami, Florida 33132 Tel: (305) 961-9320; Fax: (305) 530-7139 Email

s. To avoid contravening the Orders of this Court and Judge Middlebrooks' Order, Respondent has determined that it must seek permission from Judge Middlebrooks to unseal or partially unseal his Order. 3. An additional seven (7) days is requested to prepare and receive a ruling on that motion. This request