Subject: RE: Proposed Schedule to Resolve CVRA Case within Twelve Months Date: Thu, 13 Mar 2014 18:24:49 +0000 Importance: Normal Perhaps this could be the vehicle where we focus the Court and victim's attention on the legal issues that can be resolved on agreed facts without having to flesh out all of the irrelevant points Cassell wants to address regardless of the fact that they do not advance his client's legal claims? In other words, if we are going to compress the schedule, then the issues need to be narrowed for resolution. I think we need to make clear to the Court that doing everything that Cassell would like in a compressed timeframe would not constitute a reasonable schedule. Sent: Thursday, March 13, 2014 2:10 PM u je : ropose c e ue o esove ase wi in we ve onths This is an e-mail from Cassell suggesting that the parties might propose a schedule to Judge Marra to resolve the case within the next 12 months, since they believe the statute of limitations will expire by the end of that period. The court has already acknowledged that it cannot order the government to prosecute Epstein. Even if the court finds the non-prosecution agreement was invalid because the CVRA had been violated, and sets it aside, the government still has the unfettered discretion to determine the appropriate action in the Epstein criminal case. If we don't agree to some proposed schedule, Cassell will again use that to argue how unreasonable the government is. I think the appropriate course would be to advise the Court the government will adhere to any reasonable time limits set by the Court, so we don't appear to be dragging our feet on purpose. From: Paul Cassell mailto:[email protected]] Sent: Thursday, March 13, 2014 1:50 PM Cc: Brad Edwards (bradepathtojustice.com) Subject: RE: thanks Thanks for the update — we look forward to hearing from EOUSA. As mentioned on the phone, Brad and I may be in touch with you soon about a schedule that would bring the ca