Epstein Secrets

CTIMS IN CRIMINAL PROCEDURE 3-39 (3d ed. 2010) (describing reforms from a historical perspective), see also, e.g., 18 U.S.C. § 3771(a) (2012). T See BELOOF, CASSELL & TWIST, supra note 6, at 3-39 (describing the history of victims’ rights in American law and the early days of the modern movement). 8 See, e.g., William F

rts concluded that a victim of uncharged conduct should not be afforded statutory protections.'°! Yet none of these cases—United States v. Turner,'°? Searcy v. Paletz,'® or Searcy v. Skinner'°*—provide strong support for OLC’s position. Turner is a particularly poor fit. Although OLC’s memorandum characte

ctims in Criminal Procedure 3-39 (3d ed. 2010) (describing reforms from a historical perspective); see also, e.g., /8 U.S.C. § 377/(a) (2012). 7 See Beloof, Cassell & Twist, supra note 6, at 3-39 (describing the history of victims’ rights in American law and the early days of the modern movement). 8 See, e.g., William F

that a victim of uncharged conduct should not be afforded statutory protections. !°! Yet none of these cases - United States v. 10 104 Turner, !9? Searcy v. Paletz, !°3 or Searcy v. Skinner - provide strong support for OLC's position. Turner is a particularly 9 See 42 U.S.C. § 10607(c). % Td. § 10607(

J. Int'l L. 37 (1996); Steven J. Twist, The Crime Victims’ Rights Amendment and Two Good and Perfect Things, 1999 Utah L. Rev. 369. 7 See generally Beloof, Cassell & Twist, supra note 6, at 29-38; Douglas Evan Beloof, The Third Wave of Victims' Rights: Standing, Remedy and Review, 2005 BYU L. Rev. 255; Cassell, Balancin

ainst individuals who have not been convicted of a crime." Jn re W.R. Huff Asset Mgmt. Co., 409 F.3d 555, 564 (2d Cir. 2005) (emphasis added); accord Searcy v. Skinner, No. 6:06-1418-GRA-WMC, 2006 WL 1677177, at 2 (D.S.C. June 16, 2006). Like the constitutional amendment it was patterned on, the CVRA exte