Thanks - B1W I forwarded to MI and El - I think you used the old e-mail addresses. Ori inal Messa e From: . (USAFLS) Sent: Thursda , March 17, 2011 6:14 PM To: USAFLS Cc: (USAFLS); [email protected]; (USAFLS); (USAFLS); '[email protected]' Subject: Call from Newsweek Hi Received a voicemail from Newsweek (which now includes Conchita Sarnoff) while I was at the doctor's office from Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein prosecution. My guess is it is either Cassell's letter or response thereto. They are going to print tomorrow. From: (USAFLS) ‹ > Sent: Thursday, March 17, 2011 6:14 PM To: (USAFLS) Cc: (USAFLS); (USAFLS); [email protected] Subject: Call from Newsweek (USAFLS); Hi Received a voicemail from Newsweek (which now includes Conchita Sarnoff) while I was at the doctor's office from Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein prosecution. My guess is it is either Cassell's letter or response thereto. They are going to print tomorrow. From: (USAFLS) < Sent: Thursday, March 17, 2011 12:56 PM To: Paul Cassell Cc: (USAFLS); Brad Edwards Subject: RE: Government's Position on Several Pending Issues? Still Waiting for Answer Paul, 1. Yesterday, I provided you with the name and phone number for , OPR Acting Associate Counsel, who received your December 10, 2010 letter to Mir. asking for an investigation of the Jeffrey Epstein prosecution. 2. The government will not be making initial disclosures to plaintiffs, because we do not believe Fed.R.Civ.P. 26 applies to this matter. EFTA00206357
3. The CVRA applies to the criminal case which has been filed in district court, where an individual is deemed to be a "victim," not any civil litigation which may be initiated to enforce those claimed rights. We do not believe there is any ht to in this case. Moreover, we do not believe that whatever Kenneth Starr or may have said to this office, or what this office said to Kenneth Starr or Lilly Ann , has any bearing on whether a duty existed under 18 U.S.C. 3771(a) to consult with plaintiffs prior to entering into a non-prosecution agreement, where no charges were filed in the district court. We will respond to your motion seeking access to this information. 4. As I understand the Magistrate Judge's order in Jane Doe No. 2 v. Jeffrey Epstein (D.E. 226), you must give notice to Epstein, prior to making certain correspondence public by either filing the correspondence in a court file, attaching it to a deposition, releasing it to the media, or publically disseminating it in any other fashion. D.E. 226 at 4. Presumably, Epstein will raise any objections he believes are appropriate, and the court will resolve the matter. The U.S. Attorney's Office has no independent objection to the filing of "an unsealed, unredacted pleading reciting the U.S. Attorney's correspondence." In stating that the U.S. Attorney's Office has no independent objections, we wish to make clear that we are not, and cannot, relieve the plaintiffs of their obligation to comply with the Magistrate Judge's order by giving the appropriate notice to Epstein (D.E. 226). Thank you. From: Paul Cassell [mailto: Sent: Tuesda , March 15, 2011 7:21 PM To: USAFLS Cc: . (USAFLS); Brad Edwards Subject: RE: Government's Position on Several Pending Issues? Still Waiting for Answer Dear Brad and I have received Mr. letter of today. We are deeply disappointed. We will file our court pleadings on Friday. Mr. - again. letter still leaves unanswered a number of questions, which I am writing to raise with you - 1. You still have not provided, as you promised you would, the name of the person coordinating the OPR investigation. As a result we have not been able to obtain any information about the status of the EFTA00206358
investigation. Just to be clear, we intend to include in our filing information that OPR has begun an investigation and to include the information that we currently have about — we assume that making that information public will not compromise OPR's work. 2. We will be making initial disclosures to you under the Federal Rules of Civil Procedure shortly. We have not heard back from you on whether you will be making parallel disclosures. Accordingly, we understand your position to be that you are not obligated to provide to us any documents under Rule 26. 3. We understand your position to be that, despite the "best efforts" clause in the CVRA and your obligation to treat victims with fairness, you can withhold evidence from the victims that will help them prove CVRA violations. For example, we understand you to take the position that you can withhold the other half of the U.S. Attorney's correspondence, correspondence between the Department and Ken Starr and Lillian on behalf of Epstein, and information about role in the Epstein case. In short, we understand you to be asserting a blanket position that you can withhold information that will help prove the victims' CVRA case. If this is incorrect, please advise us promptly. If we have misunderstood you and you are willing to provide us relevant information, we will promptly provide you with a list of such information. If we have understood you correctly, we will be filing a motion with the Court shortly to block the Justice Department from suppressing such highly relevant information. 4. You still have not given us your position on the victims' motion to file an unsealed, unredacted pleading reciting the U.S. Attorney's correspondence. What is your position on that motion: We have been asking for your position on this motion for some time now. If we have not heard back from you by c.o.b. Wednesday, March 16, 2011, we will include in our pleadings the following statement: "The Justice Department attorneys handling this case have been contacted several times for their position on this issue but have refused to respond to give their position." Thanks you in advance for your assistance. Sincerely, Paul Cassell, Co-Counsel for Jane Doe Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah Voice: Fax: Email: http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul EFTA00206359
CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. From: (USAFLS) Sent: Thursday, March 17, 201112:43 PM To: (USAFLS) Cc: (USAFLS); . (USAFLS); (USAFLS); (USAFLS) Subject: RE: Contact from Vanity Fair re Epstein related to Conflict of Interest Thank you. From: (USAFLS) Sent: Thursda , March 17, 2011 12:42 PM To: (USAFLS) (USAFLS); (USAFLS); (USAFLS); (USAFLS); (USAFLS) Subject: Contact from Vanity Fair re Epstein related to Conflict of Interest (USAFLS); Hi — I received the following voicemail from Vanity Fair magazine this morning. As per usual, I will leave it to you to respond. This is a transcription so if it reads strangely, that is why: Yes, Assistant U.S. Attorney . This is John Connelly from Vanity Fair Magazine. I think I tried to talk to you a couple years ago about a guy named Jeffrey Epstein. Anyway, ummm I need to speak to you or maybe somebody if you are uncomfortable speaking to me totally on background your public information office because something has come to me which is a bit troubling about the U.S. Attorney's decision to not prosecute Jerry Jeffrey Epstein as long as he took that plea where he was allowed out of his cell 16 hours a day 6 days a week not a bad deal umm but is has to do with the relationship of your former AG and Mr. ummm Epstein's lawyer. It seems as though there was certainly a possible conflict and I need somebody to talk to about that whether it is you or anybody else I don't care. John Connelly. Vanity Fair Magazine. I really appreciate your call and off the record I heard you did great work on that case. Thank you so much. Assistant U.S. Attorney Fax From: [email protected] EFTA00206360
Sent: Friday, March 18, 2011 3:31 PM To: . (USAFLS) Subject: Your CourtLink dockets have arrived Attachments: CourtLink_Dockets_728652_3.18.2011_153050541.zip Attached is information ordered from CourtLink by ANN on 3/18/2011. This information is in PDF format, which you can open with Adobe Acrobat. If you do not have Adobe Acrobat, you may download Adobe Acrobat Reader from http://www.adobe.com/products/acrobat1readstep2.html. Contact LexisNexis Customer Support or your own IT Department for assistance. This file is currently zipped and must be unzipped before you will be able to open it. You can use PKUnzip or WinZip to unzip the file. If you do not have either program, you may download Winzip from http://www.winzip.com. Contact LexisNexis Customer Support or your own IT Department for assistance. If you have difficulty opening or using this file, please contact LexisNexis Customer Support at 1-888-311-1966 or go to http://supportlexisnexis.com/courtlinkemail. If you would like to monitor additional cases, you can set up a TRACK to notify you of unfolding activity in existing cases. Please visit https://CourtLink.LexisNexis.comlTrack/TrackSetup.aspx. PLEASE NOTE: If there is no file attached to this email, the attachment may have been blocked by your firm's email system for security reasons. Please contact your email system administrator, IT Department, or LexisNexis Customer Support for further assistance. This is a send only email. Please do not reply to this email. If you are experiencing any issues in using the LexisNexis(r) CourtLink(r) service, please feel free to Contact LexisNexis Customer Support. CourtLink(r) 888-311-1966 CourtLink Classic(r) 877-430-2990 Customer Support team is available 24 hours a day, 7 days a week to assist you. For a web mail form for Customer Support please go to the following page: http://supportlexisnexis.com/courtlinkemaiVdefauft.asp?vcForm=Courtlink_Email_Form1&61=Continue LexisNexis is a trademark and CourtLink and CourtLink Classic are registered trademarks of LexisNexis. From: (USAFLS) Sent: Thursday, March 17, 2011 6:24 PM To: (USAFLS) Subject: Re: Call from Newsweek I don't have it. She left a voicemail Original Message ---- From: (USAFLS) Sent: Thursda . March 17, 2011 06:22 PM To: . (USAFLS) Subject: Re: Call from Newsweek Can u send me conchita"s email? EFTA00206361









