From: To: Subject: Fwd: Motion to Compel and S.J. Briefing Schedule Date: Wed, 08 Mar 2017 16:56:51 +0000 Importance: Normal Can we talk later this afternoon? Begin forwarded message: From: Paul Cassel Date: March 8, 2017 at 8:51:03 AM EST 11 Cc: uelect: RE: Motion to Compel and S.J. Briefing Schedule Dea I'm writing to express some concerns about the Government's recent response to our most recent discovery requests and to request a stipulated briefing schedule for the summary judgment response and reply. As you know, on or about August 31, 2016, Brad and I served you with a supplemental discovery request on various issues. Without repeating all those requests here, I would highlight one of them: Supplemental Discovery Request 3. Any emails to or from FBI employees egarding the prosecution (or non-prosecution) of the Epstein case, any of the Epstein victims, or federal prosecutors obtaining benefits from Epstein. I later met with you and your team on the phone and gave very specific guidance about where the responsive emails would be, specifically, in the accounts for the FBI agents mentioned above. After taking months, and after promising us (in exchange for our agreement to extend deadlines) that we would be getting something substantive, we not only received nothing at all, but it appears obvious that no search for the requested information was accomplished. For example, despite all the names listed above the email we received from .tated: "I asked the FBI to conduct a search of the e-mail accounts of Special Agents Given the nature of the materials that we are seeking, it appears that the U.S. Attorney's Office is intent on not locating the materials that we are seeking. We intend to file a motion to compel production of these materials on or about Tuesday, March 14 — making all of these points clearly for Judge Marra, so that he can draw his own conclusions about what is happening. We wanted to make one last effort to resolve thi