EFTA00206173

To: 
(USAFLS); 
(USAFLS) 
Subject: Fw: Call from Newsweek 
Sorry it keeps getting misdirected 
From: 
(USAFLS) 
Sent: Thursda , March 17, 2011 07:52 PM 
To: 
USAFLS ; 
<eis@miamidade.gov>; 
(USAFLS) 
Cc: 
(USAFLS) 
Subject: Re: Call from Newsweek 
'eis@rniamidade.govi 
Can 
and I have some of your time tomorrow? Preferably in the morning. I think we need to address this. 
From: 
(USAFLS) 
Sent: Thursda , March 17, 2011 06:32 PM 
To: 
. (USAFLS) 
Subject: Re: Call from Newsweek 
I am wading through some of it now. 
From: 
(USAFLS) 
Sent Thursda , March 17, 2011 06:31 PM 
To: 
(USAFLS) 
Subject: Re: Call from Newsweek 
No 
Origirat 
From: 
(USAFLS) 
Sent: Thursda , March 17, 2011 06:30 PM 
To: 
. (USAFLS) 
Subject: RE: Call from Newsweek 
BTW, do we know exactly which e-mails/correspondence Cassel obtained from Epstein's counsel in the civil litigation? 
----Ori inal Messa e—
From: 
. (USAFLS) 
Sent: Thursda , March 17, 2011 6:17 PM 
To: 
(USAFLS) 
Subject: Re: Call from Newsweek 
Thx. Sending from bberry 
From: 
(USAFLS) 
Sent: Thursda , March 17, 2011 06:15 PM 
To: 
. (USAFLS) 
Subject: RE: Call from Newsweek 
Thanks - BTW I forwarded to I= and • 
- 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); 
(USAFLS); 
(USAFLS); 
'eis©miamidade.govi 
EFTA00206353

Subject: Call from Newsweek 
Hi 
Received a voicemail from Newsweek (which now includes 
) 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: 
Sent: 
To: 
Cc: 
Subject: 
(USAFLS) < 
Monday, March 21, 2011 9:57 AM 
(USAFLS) 
(USAFLS); 
(USAFLS) 
RE: Planned response to tomorrow's filing by Cassell 
At the conclusion of the emergency hearing in July 2008, the court asked the parties to meet and decide 
whether there were any disputed facts, so the court could schedule a hearing. 
We told Edwards the only 
relevant fact was whether any charges had been filed against Epstein in federal court, and it was not disputed 
the answer was "no." Edwards disagreed and attempted to include other "facts" which he believed to be 
relevant to the resolution of the legal question of whether the government had a duty to consult with the 
victims under 18 U.S.C. 3771(a)(5). 
I don't believe the filing of the motion you suggest will achieve the result of preemptively striking Cassell's 
motion to enforce. 
The court will have to decide whether the resolution of any disputed facts is required, in 
order to resolve the legal issue. 
The government says no; the victims say yes. The court is not likely to 
resolve this question without looking at the factual issues the victims contend are relevant, and considering the 
arguments of each side as to why those issues are, or are not, relevant to the resolution of the dispute. 
If we file the motion you suggest, the victims will oppose it and argue the facts alleged in their motion to 
enforce are indeed relevant, and should be considered. We will argue the victims' factual issues are not 
material and/or relevant, and the court should only consider that no federal charges were ever filed against 
Epstein. This is what is going to happen when the government responds to the victims' motion to enforce. 
We have a number of arguments that victims are not entitled to full-blown discovery, as a party would be 
entitled to in a true civil action. It's more than a little ironic that Cassell told us he had done these cases all 
over the country, and he had never had to file a complaint. Now he claims the Federal Rules of Civil 
Procedure, to say nothing of Brady and Giglio, also apply. 
From: 
Sent: Sunda 
To: 
Cc: 
(USAFLS) 
March 20, 2011 2:40 PM 
USAFLS 
(USAFLS); 
(USAFLS) 
Subject: Planned response to tomorrow's filing by Cassell 
Hi 
— What would you think about this plan for a response to tomorrow's filing by Cassell? Rather than 
wait our two weeks to file a response to his onslaught, we simply file something tomorrow (after Cassell's is 
EFTA00206354

filed) or Tuesday that is entitled: Request for Ruling on Emergency Petition. We can state that the petition was 
fully-briefed back in 2008 and that, as you stated in DE17, the only relevant fact is that Epstein entered a guilty 
plea in state court. Their motion for summary judgment is an attempt to enlarge their "emergency petition" into 
a full fledged cause of action and 18 USC 3771(d)(6) specifically states that there is no separate cause of action 
for a violation, so they cannot file a Complaint. They also cannot reopen a plea or sentence under 3771(d)(5). 
You may have already seen this, but take a look at US v. Hunter, 548 F3d 1308 (10th Cir 2008), where Cassell 
tried to override the limitation on victims' rights to appeal sentences. Cassell represented the victims, and the 
10'h Circuit has a good discussion on how victims cannot override prosecutorial discretion, quoting from 18 USC 
377I(d)(6). 
Cassell has, however, been successful in the 11th, in In re Stewart, 552 F.3d 1285 (11th Cir. 2008), where Cassell 
filed a writ of mandamus to have the Middle District of Florida recognize home purchasers as victims in a guilty 
plea to an Information by a bank executive. The executive was pleading guilty to money laundering where the 
underlying criminal activity involved charging fraudulent loan origination fees to the victims. 
With regard to the issue of discovery, I think that the language in 18 USC 3771(d)(6) that there cannot be a 
separate cause of action is helpful. That means that this is not truly a civil case — it should have been filed 
annexed to a civil case, where civil discovery rules would not apply. Since there is not criminal case, the Clerk's 
Office filed it with a civil case number, but the Court has the discretion to decide that discovery is not 
appropriate. See Alphin v. United States, 809 F.2d 236 (4th Cir.), cert. denied 480 U.S. 935 (1987) (district court 
may suspend or limit application of civil rules in summary proceedings). 
Assistant U.S. Attorney 
From: 
=, 
(USAFLS) <-> 
Sent: 
Monday, March 21, 2011 4:11 PM 
To: 
(USAFLS), 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Subject: 
FW: Epstein 
Conchita Samoff is now calling DC — see emails below. 
Her first question (separate email) was based on her "understanding' that the appellate Chief in DC 
had approved all actions in that case (that was not the case) 
From: 
(USAFLS) 
Sent: Monday, March 21, 2011 4:09 PM 
To:  
(SMO) 
 
Cc: I 
(SMO); 
Subject: RE: Epstein 
She has not called me at all on this. 
(USAFLS) 
EFTA00206355

From: 
Sent: Monda 
To: 
Cc: 
Subject: RE: 
(SMO) 
March 21, 2011 4:01 PM 
USAFLS) 
. (SMO) 
Epstein 
Thanks - she doesn't appear to know this letter exists, as her two questions to me were: 
1) 
Who was Acosta's boss in 2007 
2) 
Why was the defense team allowed to negotiate with Main Justice 
Are you guys talking to her at all on this? 
From: 
(USAFLS) 
Sent: Monda , March 21, 2011 3:22 PM 
To: 
(SMO) 
Subject: Epstein 
Attached letter from John Roth to Epstein attorneys. 
According to the prosecutor, the non-pros deal was already offered, but the defense wanted an 
independent review of the facts anyway. 
From: 
Sent: Mona 
To:
(USAFLS) 
, March 21, 2011 3:18 PM 
(USAFLS) 
«080623 DAG Ltr to Lefkowitz and Starr.pdf» 
From: 
Sent: 
To: 
Subject: 
Thx. Sending from bberry 
(USAFLS)
). 
Thursday, March 17, 2011 6:17 PM 
(USAFLS) 
Re: Call from Newsweek 
Ori inal Messa e 
From: 
(USAFLS) 
Sent: Thursda , March 17, 2011 06:15 PM 
To: 
. (USAFLS) 
Subject: RE: Call from Newsweek 
EFTA00206356

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); WAF@miamidade.goV; 
(USAFLS); 
(USAFLS); 
'eis@miamidade.gov' 
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); eis@miamidade.gov 
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: 
DocketDelivery@CourtLink.LexisNexis.com 
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 
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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

---- Or  ir
Aessag
-
From: 
(USAFLS) 
Sent: Thursda , March 17, 2011 06:13 PM 
To: 
, 
USAFLS 
Cc: 
(USAFLS); 
<1=1
1.>: 
(USAFLS); 'eis@miamidade.gov' <eis@miamidade.gov> 
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: 
Friday, March 18, 2011 4:45 PM 
To: 
(ODAG) (JMD) 
Subject: 
RE: Can you call me? It is urgent 
I will wait for you. There may be a Newsweek story tomorrow about Alex's relationship with Starr and 
Lefkowitz and the special treatment for Epstein. 
Assistant U.S. Attorney 
Fax 
From: 
(ODAG) (SMO) 
Sent: Frida March 18, 2011 4:43 PM 
To: 
. (USAFLS) 
Subject: Re: Can you call me? It is urgent 
In meetings with the DAG (and others) until 5:30. Can it wait until then or should I step out? 
From: 
(USAFLS) 
Sent: Friday, March 18, 2011 04:26 PM 
To: 
(ODAG) 
EFTA00206362

Subject: Can you call me? It is urgent 
Assistant U.S. Attorney 
Fax 
From: 
(USAFLS) 
Sent: 
Tuesday, March 15, 2011 7:37 PM 
To: 
(USAFLS) 
Cc: 
(USAFLS); 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Subject: 
RE: Epstein 
Agreed. Agents will be conducting the interview in Australia tomorrow night our time (Thursday Australia 
time). After that, I will know what we are really working with and will finish it up as quickly as I can. There is 
a lot to digest and unfortunately I have a lot of other pressing matters, too, but I am working as fast as I can. 
Assistant U.S. Attorney 
Fax 
From: 
(USAFLS) 
Sent: Tuesda March 15 2011 6:51 PM 
To: 
. (USAFLS 
Cc: 
(USAFLS); 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Subject: Epstein 
Hi M, 
I think you mentioned last week that you were preparing a memo addressing some of the legal and strategic 
issues relating to a potential new investigation into Epstein and/or other targets. Once you've done that, we 
EFTA00206363

should probably set aside some time to chat about the case generally. Also, 
reached out to • 
and me last week and raised some issues that we can discuss as well. Thanks. 
From: 
Paul Cassell < 
Sent: 
Tuesday, 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 
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." 
EFTA00206364

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 
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: 
Tuesday, March 15, 2011 7:40 PM 
To: 
(USAFLS); 
(USAFLS) 
Cc: 
(USAFLS);  
 
 
 
(USAFLS) 
Subject: 
FW: Government's Position on Several Pending Issues? Still Waiting for Answer 
and M, 
Here is Cassell's response to our letter. 
On March 1, 2010, I sent an e-mail to 
at 
OPR, to whom I had referred Cassell's letter asking for an inquiry. 
I asked 
if OPR had a policy 
about complainants having direct contact with investigating attorneys, since I was reluctant to provide 
name in the absence of consent. 
has not responded to my e-mail. I intend to provide 
the general phone number for OPR to Cassell. 
EFTA00206365

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 
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." 
EFTA00206366

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/default.asp?PersonID=57&name=Cassell,Paul 
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: 
Tuesday, March 15, 2011 8:49 PM 
To: 
(USAFLS) 
Subject: 
Re: Epstein 
Thanks - I know you are swamped. No rush, I just figured we should all talk since this case has so 
many moving parts. 
(USAFLS) 
March 15, 2011 07:37 PM 
(USAFLS) 
(USAFLS); 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Subject: RE: Epstein 
EFTA00206367

Agreed. Agents will be conducting the interview in Australia tomorrow night our time (Thursday Australia 
time). After that, I will know what we are really working with and will finish it up as quickly as I can. There is 
a lot to digest and unfortunately I have a lot of other pressing matters, too, but I am working as fast as I can. 
Assistant U.S. Attorney 
Fax 
From: 
(USAFLS) 
Sent: Tuesda March 15 2011 6:51 PM 
To: 
.(USAFLS 
Cc: 
(USAFLS); 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Subject: Epstein 
Hi M, 
I think you mentioned last week that you were preparing a memo addressing some of the legal and strategic 
issues relating to a potential new investigation into Epstein and/or other targets. Once you've done that, we 
should probably set aside some time to chat about the case generally. Also, 
reached out to • 
and me last week and raised some issues that we can discuss as well. Thanks. 
From: 
 
(USAFLS) 
Sent: 
Tuesday, March 15, 2011 8:40 PM 
To: 
(USAFLS); 
 
(USAFLS) 
Cc: 
(USAFLS); 
(USAFLS) 
Subject: 
Re: Government's Position on Several Pending Issues? Still Waiting for Answer 
At the risk of stating the obvious, Cassell's approach seems to be to ratchet up the attacks against the 
office whenever he doesn't get exactly what he wants. Most of his e-mail deals with his efforts to 
embarrass the Office rather than the legal issue before Judge Marra. 
That being said, his statement that OPR "has begun an investigation" is not only irrelevant, but 
possibly incorrect. Since there is pending litigation, my guess is that OPR has not yet begun an 
investigation. My understanding based on another experience as well as on comments from OPR at 
the NAC is that they specifically do not begin investigations while there is pending litigation on the 
same subject matter as the referral. The fact that Cassell is the one who wrote the letter that we 
forwarded to OPR matters here as well. Cassell simply made an accusation and he is now trying to 
use the fact of an OPR investigation to give the illusion that there must be some merit to the allegation. 
I could be mistaken and it may just be semantics, but he seems wrong on this. 
From: 
(USAFLS) 
Sent: Tuesday, March 15, 2011 07:39 PM 
EFTA00206368

To: 
USAFLS); 
USAFLS) 
Cc: 
(USAFLS); 
. (USAFLS) 
Subject: FW: Government's Position on Several Pending Issues? Still Waiting for Answer 
and M, 
Here is Cassell's response to our letter. 
On March 1, 2010, I sent an e-mail to 
at 
OPR, to whom I had referred Cassell's letter asking for an inquiry. 
I asked 
if OPR had a policy 
about complainants having direct contact with investigating attorneys, since I was reluctant to provide 
name in the absence of consent. 
has not responded to my e-mail. I intend to provide 
the general phone number for OPR to Cassell. 
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 
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. 
EFTA00206369

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 
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. 
EFTA00206370

From: 
Sent: 
To: 
Cc: 
Subject: 
. (USAFLS) <WFerrer@usa.doj.gov> 
Wednesday, March 16, 2011 10:15 AM 
(USAFLS); 
(USAFLS) 
(USAFLS); 
. (USAFLS) 
RE: Government's Position on Several Pending Issues? Still Waiting for Answer 
Excellent point. Please make OPR aware of this situation so that we can provide guidance. We need 
to clarify this point with Cassell before he files his motion on Friday. 
is right: this is a classic 
smear campaign in order to distract the court from the legal/statutory issue before it. 
From: 
(USAFLS) 
Sent: Tuesda March 15, 2011 8:40 PM 
To: 
USAFLS); 
USAFLS 
Cc: 
(USAFLS); 
. (USAFLS) 
Subject: Re: Government's Position on Several Pending Issues? Still Waiting for Answer 
At the risk of stating the obvious, Cassell's approach seems to be to ratchet up the attacks against the 
office whenever he doesn't get exactly what he wants. Most of his e-mail deals with his efforts to 
embarrass the Office rather than the legal issue before Judge Marra. 
That being said, his statement that OPR "has begun an investigation" is not only irrelevant, but 
possibly incorrect. Since there is pending litigation, my guess is that OPR has not yet begun an 
investigation. My understanding based on another experience as well as on comments from OPR at 
the NAC is that they specifically do not begin investigations while there is pending litigation on the 
same subject matter as the referral. The fact that Cassell is the one who wrote the letter that we 
forwarded to OPR matters here as well. Cassell simply made an accusation and he is now trying to 
use the fact of an OPR investigation to give the illusion that there must be some merit to the allegation. 
I could be mistaken and it may just be semantics, but he seems wrong on this. 
From: 
Sent: Tuesda 
To: 
Cc: 
Subject: FW: Government's Position on Several Pending Issues? Still Waiting for Answer 
(USAFLS) 
March 15, 2011 07:39 PM 
USAFLS); 
(USAFLS); 
USAFLS) 
I. (USAFLS) 
and M, 
Here is Cassell's response to our letter. 
On March 1, 2010, I sent an e-mail to 
OPR, to whom I had referred Cassell's letter asking for an inquiry. 
I asked 
about complainants having direct contact with investigating attorneys, since I was 
name in the absence of consent. 
has not responded to my e-mail. I 
the general phone number for OPR to Cassell. 
r
ad a policy 
at 
reluctant to provide 
intend to provide 
EFTA00206371

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 
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." 
EFTA00206372