EFTA00014133.pdf
92.7 KB
Extraction Summary
4
People
3
Organizations
1
Locations
1
Events
2
Relationships
3
Quotes
Document Information
Type:
Email chain
File Size:
92.7 KB
Summary
An email exchange between Paul Cassell (representing victims) and the US Attorney's Office (USAFLS) regarding the wording of a protective order. The order concerns the disclosure of the Non-Prosecution Agreement (NPA) to the victims. Cassell urges speed, citing government representations that 'Epstein is trying to ignore the agreement,' and negotiates the timing of when victims must sign acknowledgments of the protective order.
People (4)
| Name | Role | Context |
|---|---|---|
| Paul Cassell | Attorney/Judge |
Counsel for Petitioners (victims); negotiating terms of protective order.
|
| Brad Edwards | Attorney |
Counsel for Petitioners; recipient of emails.
|
| Jeffrey Epstein | Defendant |
Mentioned as 'trying to ignore the agreement' (Non-Prosecution Agreement).
|
| [Redacted Name] (USAFLS) | Government Official |
Sender of the top email; representing the U.S. Attorney's Office.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| USAFLS |
U.S. Attorney's Office for the Southern District of Florida (implied by acronym).
|
|
| USAO |
United States Attorney's Office.
|
|
| University of Utah |
Affiliation of Paul Cassell (S. J. Quinney College of Law).
|
Timeline (1 events)
2008-08-14
Government representations made regarding Epstein trying to ignore the agreement.
Unspecified (likely court or legal correspondence)
Government Representatives
Locations (1)
| Location | Context |
|---|---|
|
Address in Paul Cassell's signature block.
|
Relationships (2)
Addressed together as recipients; Cassell refers to 'As Brad mentioned'.
Cassell represents victims (Petitioners) against Epstein's interests.
Key Quotes (3)
"we need to see this document quite quickly in view of the Government's representations yesterday that Epstein is trying to ignore the agreement."Source
EFTA00014133.pdf
Quote #1
"We do not require the acknowledgment in writing prior to the non-prosecution agreement being disclosed to an authorized recipient."Source
EFTA00014133.pdf
Quote #2
"I assume that the USAO is not concerned about us as attorneys somehow ignoring the Court's protective order, so this change would focus in on the non-law trained clients."Source
EFTA00014133.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (2,972 characters)
From: [REDACTED] (USAFLS)" <[REDACTED]>
To: Paul Cassell <[REDACTED]>, Brad Edwards <[REDACTED]>
Cc: '[REDACTED] (USAFLS)" <[REDACTED]>
Subject: RE: Draft Protective Order - slight tweak
Date: Fri, 15 Aug 2008 18:24:20 +0000
Importance: Normal
Attachments: Protective_Order_v2.doc
To: Paul Cassell <[REDACTED]>, Brad Edwards <[REDACTED]>
Cc: '[REDACTED] (USAFLS)" <[REDACTED]>
Subject: RE: Draft Protective Order - slight tweak
Date: Fri, 15 Aug 2008 18:24:20 +0000
Importance: Normal
Attachments: Protective_Order_v2.doc
Judge Cassell and Brad,
I have incorporated the change suggested by Judge Cassell to paragraph (c). I also added language in paragraph (e),
referring to other victims, which also provides for petitioners' counsel to promptly provide a copy of the acknowledgment
to the U.S. Attorney's Office. The government has no doubts that counsel for petitioners will ensure the authorized
recipients are aware of the protective order and agree to abide by it, prior to disclosure. We do not require the
acknowledgment in writing prior to the non-prosecution agreement being disclosed to an authorized recipient.
referring to other victims, which also provides for petitioners' counsel to promptly provide a copy of the acknowledgment
to the U.S. Attorney's Office. The government has no doubts that counsel for petitioners will ensure the authorized
recipients are aware of the protective order and agree to abide by it, prior to disclosure. We do not require the
acknowledgment in writing prior to the non-prosecution agreement being disclosed to an authorized recipient.
We believe the petitioners' proposed protective order goes well beyond what is at issue, the government's disclosure of
the non-prosecution agreement, conditioned on limited dissemination of the document upon receipt by petitioners.
Consequently, we believe the attached proposed order, incorporating your revisions, is appropriate for the task at
hand. Thanks.
the non-prosecution agreement, conditioned on limited dissemination of the document upon receipt by petitioners.
Consequently, we believe the attached proposed order, incorporating your revisions, is appropriate for the task at
hand. Thanks.
[REDACTED]
________________________________________
From: Paul Cassell [mailto:[REDACTED]]
Sent: Friday, August 15, 2008 12:21 PM
To: Brad Edwards; [REDACTED] (USAFLS)
Cc: [REDACTED] (USAFLS)
Subject: RE: Draft Protective Order - slight tweak
From: Paul Cassell [mailto:[REDACTED]]
Sent: Friday, August 15, 2008 12:21 PM
To: Brad Edwards; [REDACTED] (USAFLS)
Cc: [REDACTED] (USAFLS)
Subject: RE: Draft Protective Order - slight tweak
Hello [REDACTED] and [REDACTED],
First, I don't know if we've been formally introduced. Nice to meet you ... electronically at least.
Second, on the language -- As Brad mentioned, we need to see this document quite quickly in view of
the Government's representations yesterday that Epstein is trying to ignore the agreement. As a result --
and in view of the difficulty of making immediate contact with our clients -- I propose one change.
Instead of this:
the Government's representations yesterday that Epstein is trying to ignore the agreement. As a result --
and in view of the difficulty of making immediate contact with our clients -- I propose one change.
Instead of this:
Prior to producing the documents to Petitioners' counsel, a copy of this Order must be provided to
counsel and their clients, who must review and acknowledge their receipt of and agreement to abide by
the terms of this Order, and who must provide a copy of that acknowledgment to the USAO.
counsel and their clients, who must review and acknowledge their receipt of and agreement to abide by
the terms of this Order, and who must provide a copy of that acknowledgment to the USAO.
How about this:
Before counsel for Petitioner's show the agreement to their clients or discuss the specific terms with
them, they must provide a copy of this Order to Petitioners, who must review and acknowledge their
EFTA00014133
them, they must provide a copy of this Order to Petitioners, who must review and acknowledge their
EFTA00014133
receipt of and agreement to abide by the terms of this Order. Counsel for Petitioner's must promptly
provide a copy of that acknowledgment to the USAO.
provide a copy of that acknowledgment to the USAO.
I assume that the USAO is not concerned about us as attorneys somehow ignoring the Court's protective
order, so this change would focus in on the non-law trained clients.
order, so this change would focus in on the non-law trained clients.
Paul G. Cassell
Ronald M. Boyce Presidential Professor of Law
S. J. Quinney College of Law
University of Utah
[REDACTED]
Salt Lake City, UT 84112
[REDACTED]
Ronald M. Boyce Presidential Professor of Law
S. J. Quinney College of Law
University of Utah
[REDACTED]
Salt Lake City, UT 84112
[REDACTED]
EFTA00014134
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