From: Paul Cassell To Brad Edwards Subject: RE: Rule 6(e) Material?? Date: Wed, 13 Apr 2011 14:23:30 +0000 Importance: Normal Dear Thanks very much for not opposing our extra time and pages request. We appreciate your help on those. Brad and I are also digesting your various pleadings. As you know, while we strenuously disagree with some of the arguments you have advanced, we have always admired the diligence with which you have represented the United States. Having reviewed your pleadings, however, we are writing to ask you to consider withdrawing the argument contained at pages 2-5 of your response to our motion to use correspondence to prove violations of the CVRA -- the arguments dealing with grand jury secrecy under Rule 6(e) of the Federal Rules of Criminal Procedure. In our view, the argument is ill-conceived and simply inaccurate. We would ask you to consider the following points. 1. Your motion does not explain which parts of our summary judgment motion -- and which parts of Exhibit A to our motion -- are protected grand jury matters. A Word search of our summary judgment motion produces only one instance of the term "grand jury" -- in paragraph 12 of our statement of facts. The paragraph reads: In September 2007, the U.S. Attorney's Office, in an effort to avoid prosecuting Epstein for his numerous sexual offenses against children, proposed to Epstein's attorneys that rather than plead to any charges relating to him molesting children, Epstein should instead plead to a single assault charge involving a telephone call made b E•stein while he was on his private jet. During this telephone call, Epstein warned against turning over documents and electronic evidence responsive to a subpoena issued by a federal grand jury in the Southern District of Florida investigating Epstein's sex offenses. U.S. Attorney's Correspondence at 49, 58. We accordingly presume that this is at least an example what you are referring to when you say tha