(OPR) From: (OPR) Sent: March 16, 2011 11:05 AM To: (OPR) Subject: FW: Referral of Cassell Request for Investigation From: a (USAFLS) Sent Wednesda March 16, 2011 10:52 AM To: (OPR) Subject Referral of Cassell Request for Investigation Ruth, Attached please find an e-mail from Paul Cassell, regarding his anticipated filing of a motion for summary judgment in this Crime Victims Rights Act case. In December, he sent the U.S. Attorney's Office a letter requesting an investigation into alleged improprieties in the negotiation of a non-prosecution agreement with Jeffrey Epstein. That request was forwarded to OPR on December 16, 2010. Cassell has been pressing me for the name of the person conducting any investigation. I declined to provide him your name, until I cleared it with you first. Does OPR have a policy about providing complainants the names of the investigating attorneys? If not, shall I just refer Cassell to the OPR general phone number? Thanks. From: Paul Cassell fmailto Sent:a r Tuesda March 15, 2011 7:21 PM To: (USAFLS) Cc: Ann C. (USAFLS); Brad Edwards Subject: RE: Government's Position on Several Pending Issues? Still Waiting for Answer Dew =, Brad and I have received/Mr. Ferrers,letter of today. We are deeply disappointed. We will file our court pleadings on Friday. Mr. Ferrer's letter still leaves unanswered a number of questions, which I am writing to raise with you -- again. 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 investigation. Just to be clear, we intend to include in our filing infonnatio has begun an investigation and to include the information that we currently have about rice Reinha — 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 front 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 C1.S. Attorney's correspondence, correspondence between the Department and Ken 08-80736-CZ-MARRA P-013952 EFTA00230470

Starr and Lillian Sanchez on behalf of Epstein, and information about Bruce Reinhart's 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 SJ. Quinney College of law at the University of Utah 332 South 1400 East, Room 101 Salt Lake Cit UT 84112-0730 Voice: Fax: 801-581-6897 Email: http://www.law.utah.edu/orofilesidefault.aso?PersonID=57&name.Cassell,Paul itiiistiape along with any/ell aaachrncnts - 7-A10:Jen:Lei. This message is intended ori; !tic,. are ne1fle intended recipient. the person respnasitrile 10 delver it to the intended distribute or copy Frs toomunicatiw. :nu htve received this message in error. • irtt.F: ::eriric. by reply ele030nic ineii and delete the originei message. Thank you. 08-80736-dV-MARRA P-013953 EFTA00230471