From: Paul Cassell <I To: "M=I (USAFLS)" Cc: MIMMUSAFLS)" k "Brad Edwards" Subject: RE: Government's Position on Page Limits Date: Fri, 18 Mar 2011 00:40:40 +0000 Importance: Normal Dear 1. Thank you for the information sent today. 2. What is the Government's position on the page limits applicable to our "summary judgment" pleading — do you believe we are under the civil rules? Or under the criminal rules? Do you believe that we need to file a separate motion for a roughly 35 page pleading with roughly 19 pages of facts? If so, what is your position on such a motion? Thank you in advance for your position. Paul Cassell, Co-Counsel for Jane Doe #1 and Jane Doe #2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. From: (USAFLS) [mailto: Sent: Thursday, March 17, 2011 10:56 AM To: Paul Cassell Cc: . (USAFLS); Brad Edwards Subject: RE: Government's Position on Several Pending Issues? Still Waiting for Answer Paul, 1. Yesterday, I provided you with the name and phone number for S OPR Acting Associate Counsel, who received your December 10, 2010 letter to Mr. Ferrer, asking for an investigation of the Jeffrey Epstein prosecution. 2. The government will not be making initial disclosures to plaintiffs, because we do not believe Fed.R.Civ.P. 26 applies to this matter. 3. The CVRA applies to the criminal case which has been filed in district court, where an individual is deemed to be a "victim," not any civil litigation which may be initiated to enforce t