Epstein Secrets

57 Attorney E-Mail(s): 644 Cesery Blvd. #250 Jacksonville, FL 32211 And By: /s! Paul G. Cassell PAUL G. CASSELL S.J. Quinney College of Law at the University of Utah 383 S. University St. 84112 casse p aw.uta .edu Utah Bar #6078 Admitted in Proceedings Below/Pro Hac Vice To Be Filed Contemporaneously This d

l Relief from Stay and requested expedited consideration. Request for Expedited Consideration At issue is an effort by the trial court judge, Judge Hafele, to retrieve apparently stolen emails containing confidential and attorney-client protected information about three sex abuse victims that have bee

a jury. 6 EFTA00804567 CERTIFICATE OF SERVICE Counsel hereby certify that a true copy of the foregoing was furnished by mail to The Honorable Donald W. Hafele, 205 N. Dixie Highway, Room 10.1216, West Palm Beach, FL 33401, and to all counsel on the attached service list, by email, on March 13, 3 018. B~I

y for Judge Hafele to enter a written order implementing his oral rulings. A further problem is that disputes have arisen about the scope of Judge Hafele's oral order. Epstein's counsel contend that they are entitled to make further copies of all the confidential materials for "appellate purposes." Th

W., L.M. and Jane Doe Co-Counsel for Plaintiff/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 H

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

Nevertheless, I think it is irrelevant because in evaluating the Rule 48 motion, then district Judge Paul G. Cassell — who is now a law professor at the University of Utah and is regarded to be a noted expert in victims' rights — concluded that under the Crime Victims' Rights Act, victims have broad rights that extend t

hat they suffered psychological, ills after being paid to give him sexually-charged massages at his Palm Beach mansion when they were as young as 14. Hafele told Epstein's attorneys they c.ouldn't go on a fishing expedition. The medical records^ he said,, can't be sought until the women are asked whether

t they suffered psychological.ills after l?eing paid.to give him sexually-charged massages at his Palm Beach mahsionwheii they were as young as 14. Hafele t_old Epstein's attorneys they c.ouldn't go on a fish1ng expeditfon. The medical records, he said,. can!t be sought until the women are asked whethe

ey E-Mail(s): [email protected] 644 Cesery Blvd. #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.

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

ey is appearing pro hac vice in this matter 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 en

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