From: To: Subject: FW: Rule 6(e) Material?? Date: Wed, 13 Apr 2011 16:24:11 +0000 Importance: Normal From: Sent: Wednesday, April 13, 2011 12:21 PM To: Cc: Subject: 1W: Rule 6(e) Material?? When is Thanks. due back from her vacation? What do you think of Cassell's comments on the government's response? From: Paul Cassell [mailto Sent: Wednesday, April 13, 2011 10:24 AM To: (USAFLS); Subject: RE: Rule 6(e) Material?? Dear (USAFLS); Brad Edwards 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 t the argument contained at pages 2-5 of your response to our motion to prove violations of the CVRA -- the arguments dealing with grand jury of the Federal Rules of Criminal Procedure. In our view, the argument simply inaccurate. We would ask you to consider the following points. 1. Your motion does not explain which parts of our summary judgment parts of Exhibit A to our motion -- are protected grand jury matters. summary judgment motion produces only one instance of the term "grand of our statement of facts. The paragraph reads: o consider withdrawing use correspondence to secrecy under Rule 6(e) is ill-conceived and motion -- and which A Word search of our jury" -- in paragraph 12 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 by Epstein while he was on his private jet. During this telephone call, Epstein