EFTA00013595.pdf

Type: pdf
Source set: data-set-8

Extracted text

LAW OFFICE
•
(
?Kt/ ( re/Pre
AND ASSOC IAT ES
July 17, 2008
AUSA
United States Attorney's Office
500 South Australian Avenue
West Palm Beach, Florida 33401
Re:
Proposed Stipulated Facts for In Re Jane Doe
Dear Ms.
Thank you for your recent proposed stipulation of facts in this case. I believe that we
have considerable common ground. At the same time, however, it appears to me that a few areas
of potential disagreement are arising. In view of that, and to avoid any misunderstandings, I
thought it might be useful to send a short letter outlining several requests and issues for
resolution before I send you back my proposed stipulated facts.
1.
I am working with two other attorneys on this case — Jay Howell in Jacksonville,
Florida, and Professor Paul Cassell in Salt Lake City, Utah. Because they were not in court for
the hearing last Friday, they will need to review a transcript of the hearing before our legal team
can agree to any stipulated facts. 1 have requested a transcript, but the preparation of it will
apparently take several weeks. Do you have any way of expediting the preparation of the
transcript by requesting it yourself? Also, as you know, my clients are indigent. As part of the
Government's responsibility to use its "best efforts to see that crime victims are .
accorded()
the rights" in the CVRA, 18 U.S.C. § 3771(c)(1), I was wondering whether the Government
would be willing to pay for the transcript.
2.
Your proposed stipulation indicates that in September 2007 the U.S. Attorney's
Office reached an agreement with Epstein to resolve the case, which was then modified in
October and December of that year. While this seems plausible, to stipulate to the facts, I would
obviously need to see copies of those three agreements. Moreover, because the circumstances
surrounding the initial agreement and its later modification are now the subject of litigation, my
client is entitled to see them. See 18 U.S.C. § 3771(aX8) (victim's r…

Open in the interactive archive →