Epstein Secrets

2822 [email protected] 5 Counsel for Plaintiff in Related Case No. 08- 80893 Paul G. Cassell, Esq. ProHac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plaint/ff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 2

for their contention that "[a]dditional in camera submissions should not be allowed on appeal." See Response (DE #525) at 2. Instead, they cite the Ninth Circuit Howell case, which held that a Court has discretion to reject newly offered evidence in an appeal of a magistrate judge's decision. Plaintiffs advan

5 E-mail: [email protected] and Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: [email protected] C

ment clearly has prior knowledge of documents that it gave to Epstein. Here, then – as the magistrate judge properly held relying on an instructive Ninth Circuit opinion (not discussed by Epstein) -- the “existence and location of the documents . . . are a ‘foregone conclusion’ and [Epstein] . . . adds littl

enue, Suite 2 Fort Lauderdale Florida 33301 Paul G. Cassell Pro liac Vice S.J. Quinney College of Law at the University of Utah. 332 S. 1400 E. Salt Lake City, UT 84112 Attorneys for Jane Doe No. 1 and Jane Doe No. 2 This daytime business address is provided for identification and correspondence purposes

tein)). Congress intended the CVRA to dramatically rework the federal criminal justice system. In the course of construing the CVRA generously, the Ninth Circuit observed: "The criminal justice system has long functioned on the assumption that crime victims should behave like good Victorian children -- seen b

posed stipulated facts. I. I am working with two other attorneys on this case — Jay Howell in Jacksonville, Florida. and Professor Paul Cassell in Salt Lake City, Utah. Because they were not in court for the hearing last Friday, they will need to review a transcript of the hearing before our legal team can a

tein)). Congress intended the CVRA to dramatically rework the federal criminal justice system. In the course of construing the CVRA generously, the Ninth Circuit observed: "The criminal justice system has long functioned on the assumption that crime victims should behave like good Victorian children -- seen b

4, 2A6.1(aX1). 18 U.S.C.A. Appeal from the United States District Court for the District of Utah (D.C. No. 2:05-CR- 13 I -TS). Jeremy M. Delicino, Salt Lake City, Utah, for Defendant-Appellant. Jack B. Haycock, Assistant United States Attorney (Thomas E. Moss, United States Attorney, with him on the brie

Robert W. Ware, United States Marshal for the Southern District of California, Appel. ken. Mime. Nos. 895, 596. United States Court of Appeals Ninth Circuit. Nov. 5, 1958. Accused, who had been indicted in the United States District Court for the Eastern District of Michigan for alleged- t mailing cir

8-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 7 of 8 Paul G. Cassell Attorney for Petitioners Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: Facsimile: E-Mall: Jay C. Howell, Esquire Attorney for Petitioners Pro Hac Vice 644 Cesery Boulevard Suite 250 Jacksonv

tein)). Congress intended the CVRA to dramatically rework the federal criminal justice system. In the course of construing the CVRA generously, the Ninth Circuit observed: "The criminal justice system has long functioned on the assumption that crime victims should behave like good Victorian children -- seen b