Epstein Secrets

2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954) 414-8033 Fax: (954) 924-1530 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane D

dings, it was reasonable for both parties to assume that their communications would remain confidential. Although the undersigned has not found any Eleventh Circuit cases that address this issue, the other Circuits that have addressed the issue have done so inconsistently. The First Circuit has held that a comp

Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: [email protected] Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane D

tion were violated when its name was listed among 246 unindicted coconspirators 'This opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en banc). 8 EFTA00208098 Case 9:08-cv-80736-KAM Document 58 Enter

2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954) 414-8033 Fax: (954) 924-1530 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane D

dings, it was reasonable for both parties to assume that their communications would remain confidential. Although the undersigned has not found any Eleventh Circuit cases that address this issue, the other Circuits that have addressed the issue have done so inconsistently. The First Circuit has held that a comp

Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Holl ood Florida 33020 Fax: Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Cit , Utah 84112 Fax: EFTA00205486 E-mail: Attorneys for Jane Doe # 1 and Jane Doe # 2 The Requests for Production a

confer with an attorney for the government and to pursue charges against Jeffrey Epstein in other Districts, their claim is not ripe. F2 Pursuant to Eleventh Circuit law, Respondent respectfully requests that the Court stay discovery in the matter pending its resolution of that motion, especially where Petitione

Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: [email protected] Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane D

The Court further ordered that all of the pleadings in the case be sealed. Id. 'This opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en bane). 6 EFTA00208120 Case 9:08-cv-80736-KAM Document 60 Enter

Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fax: E-mail: Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 841 12 Fax: E-mail: Attorneys for Jane Doe # 1 and Jane Doe # 2 15 EFTA00212586

tion were violated when its name was listed among 246 unindicted coconspirators 'This opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en banc). 8 EFTA00212579 Case 9:08-cv-80736-KAM Document 58 Enter

ally-negotiated plea deal. Paul G. Cassell teaches criminal law, criminal procedure, and crime victims’ rights at the S.J. Quinney College of Law at the University of Utah. Before coming to Utah, he was President of the Stanford Law Review, a law clerk for then-Judge Antonin Scalia on the D.C, Circuit and for Chief Just

okh-conspiracy/wp/20 | 4/04/2 | /eleventh-circuit-rules- that-discovery-can-move-forward-on-my-crime-victims-rights-act-case/ The Volokh Conspiracy Eleventh Circuit rules that discovery can move forward on my Crime Victims’ Rights Act case By Paul Cassell April 21 On Friday,the Ith Circuit ruled that discovery

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 39 EFTA00188786 Case 9:08-cv-80736-KAM Jcument 291 Entered on FLSD Doc. 01/21/2015 Page 40 of 40 CERTIFICATE OF SERVICE I certify that the fo

and Jane Doe No. 2. See Exhibit 2. The proposed motion 2 JelTrey Epstein also attempted to block discovery of materials in this case, leading to an Eleventh Circuit ruling that the victims' discovery efforts were proper. Dori Epstein, 749 F.3d 999 (11th Cir. 2014). 3 Remarkably, even though the Court directed t

egally-negotiated plea deal. Paul G. Cassell teaches criminal law, criminal procedure. and crime victims' rights at the.. Quinney College of Law at the University of Utah. Before coming to Utah. he was President of the Stanford Law Review, a law clerk for then-Judge Antonin Scalia on the D.C. Circuit and for Chief Ju

lokh-conspiracy/wp/20I 4/04/21/eleventh-ci rcu it-rules- that-discovery-can-move-forward-on-my-crime-victims-rights-act-case/ The Volokh Conspiracy Eleventh Circuit rules that discovery can move forward on my Crime Victims' Rights Act case By Paul Cassell April 21 On Friday,the I 1th Circuit ruled that discov

Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: [email protected] Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: casselp(alaw.utah.edu Attorneys for Jane Doe # 1 and Jane

tion were violated when its name was listed among 246 unindicted coconspirators 'This opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner'. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en bane). 8 EFTA00184851 CAsse€0338cov8EBB5614AW Obnaarrea0M-1EnEnt