Case Document 19-/. A W Page 1 of 7 (Aese'r/( reXtwa,/ AND ASSOCIATES July 17, 2008 A United States Attorney's Office 500 South Australian Avenue West Palm Beach, Florida 33401 Re: Proposed Stipulated Facts for In Re Jane Doe Dear Ms. Thank you for your recent proposed stipulation of facts in this case. I believe that we have considerable common ground. At the same time, however, it appears to me that a few areas of potential disagreement are arising. In view of that, and to avoid any misunderstandings, I thought it might be useful to send a short letter outlining several requests and issues for resolution before I send you back my proposed stipulated facts. 1. I am working with two other attorneys on this case — Jay Howell in Jacksonville, Florida, and Professor Paul Cassell in Salt Lake City, Utah. Because they were not in court for the hearing last Friday, they will need to review a transcript of the hearing before our legal team can agree to any stipulated facts. I have requested a transcript, but the preparation of it will apparently take several weeks. Do you have any way of expediting the preparation of the transcript by requesting it yourself? Also, as you know, my clients are indigent. As part of the Government's responsibility to use its "best efforts to see that crime victims are . accorded[) the rights" in the CVRA, 18 U.S.C. § 3771(c)(1), I was wondering whether the Government would'be willing to pay for the transcript. 2. Your proposed stipulation indicates that in September 2007 the U.S. Attorney's Office reached an agreement with Epstein to resolve the case, which was then modified in October and December of that year. While this seems plausible, to stipulate to the facts, I would obviously need to see copies of those three agreements. Moreover, because the circumstances surrounding the initial agreement and its later modification are now the subject of litigation, my client is entitled to see them. See 18 U.S.C. §