From: SAFLS)" <AVillafan usa.do. ov> To: ' (USAFLS)" < "Ferrer, Wifredo A. (USAFLS)" S)" <WJacobus®usa.doj.gov>, "Atkinson, Karen (USAFLS)" <ICAtkinson®usa.doj.gov> Cc: ' (USAFLS)" • Subject: FW: follow up today's filing -- re Victims' Rights Suit Date: Thu, 28 Oct 2010 01:16:38 +0000 Importance: Normal Attachments: DE41_20101027_Resp_to_Order_to_Show_Cause.pdf Good evening, everyone. I have attached what was filed in the District Court, and below is Judge Cassell's latest correspondence. I will let you digest and we can talk tomorrow. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 From: Paul Castel! [mallto:i 7, 2010 8:39 PM Subject: follow up today's filing 1. Via PACER, you will have seen the pleading that we have filed today. We are saddened that the U.S. Attorney's Office has not seen fit to make any concession to us, while at the same time asking us to delay filing our pleadings. Nonetheless, as a show of good faith, we are delaying filing our motion so that we can continue discussions with your Office. 2. As noted in our pleading — and as this e-mail will serve to confirm —while we are willing to continue discussions with you, we respectfully request that you immediately begin preparing your response to our motion so that if it becomes necessary for us to file it, your response can be filed quickly as well without any delay. 3. You have previously promised to review our statement of facts and tell us which facts are being disputed — and to work with us to narrow the range of disputes. As you know, we would like to work with you quickly on that effort. Could you get back to us by Friday, October 29, 2010, on that point and then have a telephone conference call with us on that date to work out the disputed facts? 4. This e-mail will also serve to confirm our request, previously raised in our October 22, 2010, letter to you, for access to correspondence relevant to Jane Doe #1 and Jane