From To Subject: FW: OPR inquiry - request for information Date: Tue, 03 May 2011 16:31:22 +0000 Importance: Normal Attachments: motion-intervene.pdf; sanctions-motion-attached.pdf This is Cassell's response to Bruce Reinhart's motion to intervene. From: Paul rakeoll [- Sent: Tuesday, May 03, 2011 12:23 PM To: Cc: Brad Edwards Subject: RE: OPR inquiry - request for information Dear As you will have seen, Bruce Reinhard has filed a motion to intervene in our Crime Victims' Rights Act case. (Since has not been served, I attach a copy of the pleading to this e-mail). As you will see, Reinhard claims that we have no factual basis for making an assertion that (for example) Reinhard improperly represented in violation of Justice Department regulations. In view of this motion, we are writing to inquire into the current status of the Justice Department's inquiry into Reinhard's conduct. We also believe that the Justice Department has access to information that will support the allegations in our summary judgment motion. We further believe that the Justice Department has access to information that will help us respond to Reinhard's claim that he was not privy to any non-public information about the Epstein case. We are therefore respectfully requesting that the Justice Department provide this information to us by Tuesday, May 10, 2011, so that we can use this information in responding to Reinhard's motion to intervene. Alternatively, if releasing the information at this time will be harmful to the Justice Department's on-going inquiry into Reinhard's conduct, we request that the Justice Department inform Judge Marra that the Reinhard situation is currently the subject of a Justice Department inquiry and that further release of information would be harmful at this time. We request an opportunity to discuss this matter with you at your earliest convenience. Thank you in advance for your assistance. Sincerely, Brad Edwards and Paul Cassell Co-Cou