Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, August 01, 2008 4:49 PM To: Lee, Dexter (USAFLS) Subject: Re: Activity in Case 9:08-cv-80736-KAM Doe I United States of America Response/Reply (Other) Hi Dexter. Got your email re Tein. Just wanted you to know that we are having huge problems with him on this and other cases. I won't deal directly with him anymore because of his threats and misrepresentations. Original Message From: Lee, Dexter (USAFLS) To: Villafana, Ann Marie C. (USAFLS) Sent: Fri Aug 01 15:03:32 2008 Subject: RE: Activity in Case 9:08-cv-80736-KAM Doe II United States of America Response/Reply (Other) Marie, His "response/reply" is more like a motion for summary judgment. Not only that, he attaches letters between counsel which should not be done under the local rules. Of course, he omitted the letter that I sent him. This is going to be fun. Dexter Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, August 01, 2008 2:58 PM To: Lee, Dexter (USAFLS) Subject: Fw: Activity in Case 9:08-cv-80736-KAM Doe'. United States of America Response/Reply (Other) Dexter, what is with this guy??? Doesn't he understand that negotiations are confidential?? Original Message From: [email protected] <[email protected]> To: [email protected] <[email protected]> Sent: Fri Aug 01 14:48:09 2008 Subject: Activity in Case 9:08-cv-80736-KAM Doe IF United States of America Response/Reply (Other) This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. ***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to 338 EFTA00193608

On Thursday, I called Edwards to tell him I still had not determine if the agreement had been publicly disclosed anywhere, but that I would be glad to meet with him and his clients next week Today, I verified with Marie that the agreement had not been filed by Michael Tein in the federal court civil litigation. Tein also called me for any information on the Jane Doe case, and I asked him if the agreement had been filed. He told me he had filed sealed motions with the court, in which references were made to the provisions of the agreement, but the agreement itself had not been filed. Since the agreement is not public, and there is a confidentiality provision in it, I don't believe we can produce it to the victims. We can still meet with Edwards and his clients, but it will be without the agreement being produced. This may not satisfy them. Edwards just filed a fifteen-page reply/response to our two-page notice to the court. Edwards' response looks more like a summary judgment motion, rather than a simple agreement or disagreement with the government's view that no further hearing is necessary. Please let me know your views on whether the agreement can be disclosed to Edwards and his clients, and whether it would be permissible/advisable to meet with Edwards and his clients. Thanks. Dexter « File: 19_plts_respgov_notice.pdf » 337 EFTA00193609