From: Paul Cassell <cassellpglaw.utah.edu> To: Paul Cassell <cassellp ilaw.utah.edu> Subject: RE: CVRA Case -- Epstein -- Moving Things Along Date: Sun, 21 Nov 2010 20:27:00 +0000 Importance: Normal Dear Brad and I are writing to express our serious concern about how things are progressing on this CVRA case. This note is prompted by the fact that it has now been nearly a month since we proposed a new, specific statement of facts to you (a full draft was e-mail to you on October 23) — and, indeed, more than two years since we proposed a set of facts to you ... all without any answers. This latest letter is also required by the fact that I hadn't heard from Dexter for some time about how the Government's response to our proposed statement of facts was coming. We had hoped to reach agreement with you on the facts in advance of the October 27 filing date. We were advised, at the last minute, that was not possible. We have continued the last several weeks to try and achieve a statement of facts, all the while being put off. Finally, I called Dexter on the morning on November 15, and Dexter told me that I should have something by the end of that day. But here we are — six days later — no statement of facts ... and, more troubling, not even the courtesy of a call letting Brad and me know what the status is or what the plans are and what caused the delay. (And remember that you were prepared to argue back in October — before Judge Marra peremptorily struck down the argument — that we had somehow delayed too long in moving the case forward!) In the mean time, our clients continue to be very eager to move forward with this case and reach a resolution. One of our clients is constantly asking for the status on this case and we have had to tell her that the U.S. Attorney's Office is putting us off and has not given us any roadmap or time table for a resolution. In light of all this, Brad and I cannot have this case delayed any further. Accordingly, we are w