From Tc Subject: Re: Government's Position on Several Pending Issues? Still Waiting for Answer Date: Wed, 16 Mar 2011 01:53:52 +0000 Importance: Normal Thx From: Sent: Tuesday, March 15, 2011 07:38 PM To: Cc: Subject: FW: Government's Position on Several Pending Issues? Still Waiting for Answer Here is Prof. Cassell's response to Willy's letter, for your records. From: Paul Cassell Sent: Tuesday, March 15, 2011 7:21 PM To: Cc: Subject: RE: Government's Position on Several Pending Issues? Still Waiting for Answer Dear Brad and I have received Mr. Ferrer's letter of today. We are deeply disappointed. We will file our court pleadings on Friday. Mr. Ferrer's letter still leaves unanswered a number of questions, which I am writing to raise with you -- again. 1. You still have not provided, as you promised you would, the name of the person coordinating the OPR investigation. As a result we have not been able to obtain any information about the status of the investigation. Just to be clear, we intend to include in our filing information that OPR has begun an investigation and to include the information that we currently have about Bruce Reinhart — we assume that making that information public will not compromise OPR's work. 2. We will be making initial disclosures to you under the Federal Rules of Civil Procedure shortly. We have not heard back from you on whether you will be making parallel disclosures. Accordingly, we understand your position to be that you are not obligated to provide to us any documents under Rule 26. 3. We understand your position to be that, despite the "best efforts" clause in the CVRA and your obligation to treat victims with fairness, you can withhold evidence from the victims that will help them prove CVRA violations. For example, we understand you to take the position that you can withhold the other half of the U.S. Attorney's correspondence, correspondence ment and Ken Starr and Lillian Sanchez on behalf of E