From: (USAFLS)" To: "M, (USAFLS)" ctl Subject: RE: CVRA case - meeting in July Date: Fri, 22 Oct 2010 17:05:55 +0000 Importance: Normal I agree with everything you have written. As far as an update, I would probably just say that the investigation is continuing but we cannot share further. A. Halatia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Fax From: MI, (USAFLS) SenSilda October 221_2010 1:02 PM To: El (USAFLS) Subject: FW: CVRA case - meeting in July Here is the latest from the plaintiffs. I don't believe we can provide any update on what is going on in the "new" Epstein case, unless the CVRA provides a right to be given status reports to a crime victim. Insofar as the rest of the e-mail, I'm going to respond to Judge Cassell by advising him that: (1) the government will agree to facts presented by plaintiffs if we agree that they are correct; (2) if plaintiffs can base a summary judgment motion based on that set of agreed facts, then the government will respond to plaintiffs' motion. However, we will not agree to an evidentiary hearing for disputed facts. I will tell him the government intends to file a motion to dismiss for lack of prosecution and failure to state a claim, insofar as the right to consultation claim. From: Paul racspii [manta Sent: FricEactober 22, 2010 12:50 PM To: M, (USAFLS) Cc: Brad Edwards Subject: RE: CVRA case - meeting in July Hi I= Still waiting to hear from you on what the current status is regarding the next criminal prosecution of Epstein. Whatsup? Also, regarding our pleading we are preparing to file, Brad reminds me of the great importance both you and we place on not "tipping off" Epstein to anything. Accordingly, we are thinking of taking out the paragraph in our pleading regarding the meeting we had with the FBI agents in July 2010. The main reason for that paragraph was to show that we have been proceeding diligently in moving this case along, inc