Epstein Secrets

aul Cassell for Jane Doe No. 1 and Jane Doe No. 2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Quinney College of Law at the University of Utah 332 South 1400 East, Room 101 Salt Lake City, UT 84112-0730 Voice: Fax: Email: http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cas

the problem with the alternative that you propose is that the jurisdictional issue and the merits issues overlap. You argue as to jurisdiction that Perlman does not apply because there is no privilege. And our argument on the merits is that there is a privilege. So privilege is at the heart of the juris

lated emails at 1 AM in the morning!). Paul Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah EFTA00209323 332 S. 1400 E. , Room 101 Salt Lake City, UT 84112-0730 (801) 585-5202 (phone) (801) 581-6897 (fax) [email protected] You ca

the problem with the alternative that you propose is that the jurisdictional issue and the merits issues overlap. You argue as to jurisdiction that Perlman does not apply because there is no privilege. And our argument on the merits is that there is a privilege. So privilege is at the heart of the juris

425 North Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954) 524-2820 [email protected] Paul G. Cassell S. J. Quinney College of Law at the University of Utah 332 S. 1400 E., Room 101 Salt Lake City, UT 84112 (801) 585-5202 [email protected] Attorneys for Plaintiffs-Appellees Jane Doe No.1 and Jane

tead Must be Challenged (If Necessary) at the Conclusion of a Case. 11 B. The District Court's Discovery Order is Not Immediately Appealable Under Perlman. 14 II. EPSTEIN HAS NOT PROVEN ANY INJURY WHICH WOULD WARRANT THIS COURT'S EXERCISE OF APPELLATE JURISDICTION 18 CONCLUSION 20 EFTA00209358

materials. 20 EFTA00209592 DATED: July 2, 2013 Respectfully Submitted, Is/Paul G. Cassell Paul G. Cassell S.J. Quinney College of Law at the University of Utah and Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Attorneys for Jane Doe No. I and Jane Doe No. 2 21 EFTA00209

tead Must be Challenged (If Necessary) at the Conclusion of a Case. 11 B. The District Court's Discovery Order is Not Immediately Appealable Under Perlman. 14 II. EPSTEIN HAS NOT PROVEN ANY INJURY WHICH WOULD WARRANT THIS COURT'S EXERCISE OF APPELLATE JURISDICTION 18 CONCLUSION 20 EFTA00209570

and Paul Cassell for Jane Doe #1 and Jane Doe #2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Quinney College of Law at the University of Utah 332 S. 1400 E. , Room 101 Salt Lake Ci , UT 84112-0730 (phone) EFTA00209595 (fax You can access my publications on http://ssrn.com/author=3016

ay. What is your position on this motion? We understand you are conferring with Washington DO), and hope that they will agree that expansion of the Perlman doctrine is clearly not in the Government's interest. Thanks for providing us whatever information you can as soon as you can. Brad Edwards and Pau

s daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. WESTLAW © 2018 Thomson Reuters. No claim to original U.S. Government Works. 12 EFTA00020552 --- PAGE BREAK ---

the time and circumstances when he will share his secrets with others and decide the extent of that sharing."), "with shame and embarrassment," see Perlman v. U.S. Dep't of Justice, 312 F.3d 100, 106 (2d Cir. 2002), vacated and remanded, 541 U.S. 970, 124 S.Ct. 1874, 158 L.Ed.2d 464 (2004), aff'd, 380 F