Epstein Secrets

g the improper deposition. AUSA secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached i

: E-mail: EFTA00208644 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 38 of 64 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the Universit of Utah Salt Lake Cit 84112 Telephone: Facsimile: E-Mail: Attorneys for Jane Doe #1 and Jane Doe #2 CERTIFICATE OF SERVICE

tion between the intervenor and the adverse party." Alvarado v. J.C. Penney Co., Inc., 997 F.2d 803, 805 (10th Cir. 1993) (quoting United States v. Oregon, 657 F.2d 1009, 1014 (9th Cir. 1981)). One illustration of the way in which Epstein is seeking to avoid ordinary litigation obligations comes from

301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: [email protected] and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah6 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: [email protected]

tion between the intervenor and the adverse party." Alvarado v. J.C. Penney Co., Inc., 997 F.2d 803, 805 (10th Cir. 1993) (quoting United States v. Oregon, 657 F.2d 1009, 1014 (9th Cir. 1981)). One illustration of the way in which Epstein is seeking to avoid ordinary litigation obligations comes from

.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale. 1 Telepho Facsimil Florida Bar No.: 542075 E-mail: and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah° 332 S. 1400 E. Salt Lake • Telephone Facsimile: E-Mai Attorneys for Jane Doe #1 and Jane Doe #2 This response is n

g the improper deposition. Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. Ms. Garvin was not advised that a non- prosecution agreement had been reached in this matter or

E, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah' 332 S. 1400 E. This daytime business address is provided for identification and correspondence purposes only and is not

oiding the improper deposition. secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached i

& LEHRMAN EFTA00615905 Case 9:08-cv-80736-KAM Document 265-1 Entered on FLED Docket 10/20/2014 Page 38 of 64 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the 11111. Attorneys for Jane Doe #1 and Jane Doe #2 CERTIFICATE OF SERVICE The foregoing document was served on October 3, 2011, on the follo

oper deposition. AUSA Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached i

stice.com EFTA00081152 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 38 of 64 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: [email protected]

oper deposition. AUSA Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached i

stice.com EFTA00179735 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 38 of 64 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: [email protected]

o the Federal Rules o Criminal Procedure 2007 Reporter 2007 Utah L. Rev. 861 * Length: 59852 words Author: Paul G. Cassell* * Professor of Law, S.J. Quinney College of Law of the University of Utah, Judge, U.S. District Court for the District of Utah, 2002-07. Thanks to Sara Sun Beale, Doug Beloof, Doug Berman, Russell

tims can attend any public deposition taken under this rule under the same conditions as govern a victim's attendance at trial. 7}5 212° Wardius v. Oregon, 412 U.S. 470, 475 (1973). iS) 3 Cassell, Proposed Amendments, supra note 4, at 873. iS) 4 Apparently in response to my argument, the Advisory Co

ight of the Crime Victims’ Rights Act 2005 Reporter 2005 B.Y.ULL. Rev. 835 * Length: 36451 words Author: Paul G. Cassell* * Professor of Law for the S.J. Quinney College of Law of the University of Utah and United States District Court Judge for the District of Utah. Thanks to Doug Beloof, Janna Tucker Davis, Meg Garvin, Wen

prosecutors whether the victim has been advised of the proposed plea and whether the victim wishes to make a statement concerning it. ©? For example, Oregon requires the court to ask the prosecutor whether the victim has been consulted about a plea and, if so, what the victim's view is: Before the judge