From: (USAFLS)" <=IMIIM> To: Paul Cassell alla> Cc: aLS)" Subject: RE: Doe USAO Date: Tue, 15 Nov 2011 00:37:05 +0000 Importance: Normal Brad Edwards Paul and Brad, We have no objections as to the extension of time until December 5. Let me check with my colleagues on the other issues, and I will let you know tomorrow. Thanks. Original Message From: Paul Cassell [mailto: Sent: Monda November 14, 2011 7:34 PM To: USAFLS Cc: . (USAFLS); Brad Edwards Subject: RE: Doe USAO Hey and =, I. As you may know, Brad is buried in a three-week jury trial, so I have not been able to consult with him at any length about the pending motion to dismiss and to stay. I also have another brief due on next Wednesday, as well as long-scheduled vacation the week of Thanksgiving. In light of all this, I am writing to inquire about the Government's position concerning a ten-day extension of the due date to respond to the motion to dismiss until December 5. 2. I noticed that you have filed two pleadings entirely under seal - your motion to dismiss and your motion to stay. And yet the vast bulk of both motions do not involve any secret grand jury material and thus (in my view) there is little reason for the vast bulk of the pleadings to be under seal. Are you willing to file redacted pleadings in the public court file? 3. If the answer to question 2 is no, what is your position on a motion from the victims asking for the court to direct the Government to file redacted pleadings in the public court file, redacting only the secret grand jury information? 4. It is our view that a bland motion for extension of time would not need to be filed under seal, because it would not disclose any grand jury materials. Here is the draft of our motion for extension of time, which we are not planning to file under seal. Please advise if you have any concerns. JANE DOE #1 AND JANE DOE #2'S UNOPPOSED MOTION FOR 10-DAY EXTENSION OF TIME TO RESPONSE TO GOVERNMENTS MOTION TO D