EFTA00014067.pdf

49 KB

Extraction Summary

5
People
1
Organizations
0
Locations
1
Events
2
Relationships
3
Quotes

Document Information

Type: Email correspondence
File Size: 49 KB
Summary

Email correspondence from August 15, 2008, between attorney Brad Edwards and the US Attorney's Office (USAFLS). They are negotiating the terms of a protective order required to disclose the non-prosecution agreement to Edwards' clients, identified as Jane Does 1 and 2. Edwards objects to a specific clause requiring his clients to formally acknowledge receipt, arguing it causes unnecessary delay.

People (5)

Name Role Context
Brad Edwards Attorney
Sender of the top email; representing victims/Jane Does; negotiating protective order terms.
Paul Cassell Attorney
Cc'd on the email chain; co-counsel for victims.
Jane Does 1 and 2 Victims/Clients
Clients of Brad Edwards; subject of the disclosure of the non-prosecution agreement.
The Judge Judge
Issued an order 'yesterday' regarding the proceedings.
[Redacted] (USAFLS) Federal Prosecutor/Official
Recipient of top email, sender of bottom email; representing the government.

Organizations (1)

Name Type Context
USAFLS
United States Attorney's Office for the Southern District of Florida (implied by acronym in email headers).

Timeline (1 events)

2008-08-14
Judge's order issued regarding the case.
Court

Relationships (2)

Brad Edwards Attorney-Client Jane Does 1 and 2
Edwards refers to 'my clients' and the email mentions disclosing the agreement to 'Jane Does 1 and 2'.
Brad Edwards Opposing Counsel USAFLS
Negotiating terms of a protective order.

Key Quotes (3)

"My only real problem with your proposed Order is paragraph C. This just further delays us from getting the agreement"
Source
EFTA00014067.pdf
Quote #1
"Getting my clients to "acknowledge receipt of the order and agree to its terms" could take awhile and cause unnecessary delay."
Source
EFTA00014067.pdf
Quote #2
"Attached please find a draft protective order regarding the disclosure of the non-prosecution agreement to you and Jane Does 1 and 2."
Source
EFTA00014067.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (1,680 characters)

From: Brad Edwards <[REDACTED]>
To: "[REDACTED] (USAFLS)" <[REDACTED]>
Cc: "[REDACTED]. (USAFLS)" <[REDACTED]>, Paul Cassell <[REDACTED]>
Subject: RE: Draft Protective Order
Date: Fri, 15 Aug 2008 15:58:44 +0000
Importance: Normal
Attachments: Protective_Order.Final.doc
This is my proposed Order. I think it comports with the Judge's order from yesterday and I think it is slightly more thorough. It is very similar to your Motion. If you are more satisfied with your wording or layout for the motion, then please incorporate the additional points made in my proposed order.
My only real problem with your proposed Order is paragraph C. This just further delays us from getting the agreement, and I do not believe the Judge placed this burden on us. I think, as I wrote in my proposed order, that it is my duty to instruct my clients on the protective order and its function and to otherwise ensure that it is not violated by my clients. Getting my clients to "acknowledge receipt of the order and agree to its terms" could take awhile and cause unnecessary delay. I plan to talk to my clients about "the agreement" and at the same time instruct them as to the rules outlined in the protective order. That is all the Judge indicated as needed to be done.
From: [REDACTED] (USAFLS) [mailto:[REDACTED]]
Sent: Friday, August 15, 2008 11:41 AM
To: Brad Edwards
Cc: [REDACTED]. (USAFLS)
Subject: Draft Protective Order
Brad,
Attached please find a draft protective order regarding the disclosure of the non-prosecution agreement to you and Jane Does 1 and 2. Please let us know if there are any changes you wish to make. Thanks.
[REDACTED]
<>
EFTA00014067

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