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f/Counter- Defendant Jeffrey Epstein VIA U.S. MAIL Paul G. Cassell S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112 [email protected] The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. Dixie Highway, Room 10.1216 West Palm Beach,
he emergency stay of proceedings, it was Epstein's counsel who worked with opposing counsel over the weekend and appeared at 8:30 a.m. before Judge Hafele in order to enter an Agreed Order nunc pro tunc so the clerk could seal the records temporarily. (App. E.) To be clear, Epstein wants a full in ca
assell S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112 [email protected] The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. Dixie Highway, Room 10.1216 West Palm Beach, FL 33401 Co-Counsel for Intervenors E.W., L.M. and Jane Doe 12
, Esq. Pro Hae Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax cassel
in which he is counsel for the plaintiffs. Judge Hafele granted his request, entered a stay, and the cas
East Las Olas Blvd., Suite 1650 Fort Lauderdale, FL 33301 [email protected] Paul G. Cassell, Esquire Pro Hae Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 [email protected] COUNSEL LIST 5 Case 9:08-cv-80119-KAM Document 331 Entered on FLSD Docket 09/29/2009 Page 6 of 6 Isidro M
9 Page 3 of 6 psychological trauma as a result of a similar "encounter" with Jeffrey Epstein at her deposition. 6. Lastly, it appears that Judge Hafele in a pending state court case (E W v. Jeffrey Epstein, Palm Beach County Circuit Court Case No. 502008CP003626) has agreed that allowing Defendant
d. #250 Jacksonville, FL 32211 (904) 680-1234 Paul G. Cassell, Esq. S.J. Quinney College of Law at the University of Utah 332 S. University St. Salt Lake City, UT 84112 (above for address purposes only) Attorney E-Mail: [email protected] Attorneys for L.M., E.W., and Jane Doe Judge Robert Carney 22
er. Ultimately, following a summary judgment motion by Edwards, Epstein dropped his lawsuit; currently pending before Judge Crow's successor, Judge Hafele, is a follow-on action, Edwards v. Epstein, for malicious prosecution by Epstein in filing his lawsuit in the first place. 6 EFTA00799319 Case 0
pursuant to court order dated April 3, 2018. Paul G. Cassell, Esq. S.J. Quinney College of Law at the University of Utah 332 S. University St. Salt Lake City, UT 84112 Telephone: (801) 585-5202 (above for address/contact purposes only, not to imply institutional endorsement) By: /s/ Paul G. Cassell Pa
ADMITTED THAT HE POSSESSED DOCUMENTS FROM THE DISK IN QUESTION Epstein has previously admitted in the related state court proceedings before Judge Hafele that he possessed documents from the disk in question. Now, before this Court, he appears to take a different position. For example, Epstein states
Entities connected to both Salt Lake City and Donald W. Hafele

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSONJane Doe
PERSONJack Goldberger
PERSONMaria Farmer
PERSON
Kenneth Marra
PERSONScott Rothstein
PERSONJack Scarola
PERSON
George W. Bush
PERSON
the University of Utah
ORGANIZATIONMichael J. Pike
PERSON
Adam D. Horowitz
PERSONKatherine W. Ezell
PERSON
Scarlett Johansson
PERSON
S.J. Quinney College of Law
ORGANIZATIONRobert C. Josefsberg
PERSON
United States
LOCATIONIsidro Manuel Garcia
PERSONRichard Horace Willits
PERSON