From: To: Paul Cassell <I Cc: SAFLS " (USAFLS (USAFLS)" <1 [=. "Brad Edwards Subject: RE: two questions: (I) certification re completion of 2013 production; (2) procedures for litigating objections to 2015 production Date: Fri, 26 Jun 2015 14:42:35 +0000 Importance: Normal Paul and Brad, I agree with your procedure in filing a motion to compel on those requests for which the government has lodged an objection. As to the request for production, I will confirm whether there are any responsive materials to requests where we objected, to ensure we are not arguing over nothing. On Supplemental Discovery Request No. 5, we did not have any surveillance videos of Jane Doe No. 1, 2, 3, or 4. I will double-check on Supplemental Discovery Request numbers 3, 4, and 6, and let you know by June 30, 2015. I will have a certification on the petitioners' First Request for Production and First Request for Admission by June 30, 2015. I am in the middle of several other projects right now. Thank you. From: Paul Catcall (mato Sent: Thursd June 25, 2015 4:14 PM To: USAFLS Cc: . (USAFLS); (USAFLS); Brad Edwards ( Subject: RE: two questions: (1) certification re completion of 2013 production; (2) procedures for litigating objections to 2015 production Dear Thank you for your (and I recent production of some emails and associated privilege log. I trust that you will note our patience and willingness to work with you on your schedules. We write with two issues: First, with regard to our 2013 discovery requests , as you know, we have been asking for some time now for the Government to certify that it has produced everything that it is going to produce on these requests. Will you please now send that certification? We understood that you were going to do that. Second, we also have a question about 2015 discovery requests, concerning Mr. Dershowitz and other subjects. We've seen your response to our Request for Admissions (RFAs) and Request for Production (