EFTA00014133.pdf

Type: pdf
Source set: data-set-8
Extracted text

From: 
(USAFLS)" 
 
To: Paul Cassell  
>, Brad Edwards < 
Cc: ' 
 (USAFLS)" < 
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. 
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. 
From: Paul Cassell [malito 
Sent: Friday, August 15 2008 12:21 PM 
To: Brad Edwards' 
(USAFLS) 
Cc: 
.(USAFLS) 
Subject: RE: Draft Protective Order - slight tweak 
Hello 
and 
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: 
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 a…
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