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title: DOJ Epstein Files, Data Set 9 (EFTA00205136)
source: DOJ Epstein Files, Data Set 9
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From: Paul Cassell cassellp@law.utah.edu
Brad Edwards
Subject: RE: government position?
Date: Fri, 03 Feb 2012 00:43:21 +0000
Importance: Normal
Sorry to rush you, but following up on our email from a couple of days ago, Brad and I are hoping to file tomorrow
(1) Our motion for order directing government to file redacted, unsealed pleadings in the public court file (all three of your sealed pleadings); and
(2) A motion for the court to deny the motion to dismiss without requiring additional pleadings from us or, at a minimum, ti grant leave to file a sur-reply (we propose that our brief be of the same length as yours and due 4 weeks after the court rules on our motion (1) above).
I know there may be a “clearance” process there on this case, but hoping you can give us a position by, say, noon Friday? Thanks in advance for your help.
Paul Cassell
Co-counsel for Jane Doe #1 and Jane Doe #2
Paul G. Cassell
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Sent: Friday, January 27, 2012 5:14 PM
To: Paul Cassell; Brad Edwards
Subject: Reply re Motion to Dismiss
Hi Paul and Brad – I apologize, I didn't get Ed's email because I have been in trial prep. Here is the reply without the attachments. Brad should have received the complete documents today in the mail. The attachments are the complaints and amended complaints from the state court litigation.
I have encrypted the file because of the 6(e) material. I will send the password to Brad separately. Paul – if you want to give me a number where I can send you a text, I can text to you or leave you a voicemail with the
EFTA00205136
password.
EFTA00205137