RE: CVRA case

Hi if I may), [ ]

I believe we have communicated electronically before. As you probably know, I am co-counsel with Brad Edwards on the CVRA case concerning the Epstein (non) prosecution.

You will have seen Judge Marra's order today asking for us to explain the current situation on the CVRA case by October 23. By October 23, we plan to file a motion asking the court to declare that there were violations of the CVRA. We will be doing that on the basis of a set of fact in the case, of course.

I am writing to see if you would be interested in working with us on a stipulated set of facts? We will be in a position to give you a set of facts early to middle of next week. Would you be able to look at them quickly and let us know which facts are not dispute?

Thanks in advance for your cooperation on narrowing the factual issues in this case and any idea for helping the case to progress smoothly.

EFTA00212627

Sincerely,

Paul Cassell

Counsel for Jane Does

Paul G. Cassell

Ronald N. Boyce Presidential Professor of Criminal Law

S.J. Quinney College of Law at the University of Utah

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.

This is plaintiffs' response to the order to show cause.

From: (USAFLS)
Sent: Tuesday, October 12, 2010 3:58 PM
To: (USAFLS)
Subject: FW: CVRA case

This is plaintiffs' response to the order to show cause.

From: Paul Cassell [mailto:
Sent: Tuesda October 12, 2010 3:47 PM
To: (USAFLS)
Cc: Brad Edwards
Subject: CVRA case

Hi if I may), [ ]

I believe we have communicated electronically before. As you probably know, I am co-counsel with Brad Edwards on the CVRA case concerning the Epstein (non) prosecution.

You will have seen Judge Marra's order today asking for us to explain the current situation on the CVRA case by October 23. By October 23, we plan to file a motion asking the court to declare that there were violations of the CVRA. We will be doing that on the basis of a set of fact in the case, of course.

I am writing to see if you would be interested in working with us on a stipulated set of facts? We will be in a position to give you a set of facts early to middle of next week. Would you be able to look at them quickly and let us know which facts are not dispute?

Thanks in advance for your cooperation on narrowing the factual issues in this case and any idea for helping the case to progress smoothly.

EFTA00212627

Sincerely,

Paul Cassell

Counsel for Jane Does

Paul G. Cassell

Ronald N. Boyce Presidential Professor of Criminal Law

S.J. Quinney College of Law at the University of Utah

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.

EFTA00212628