Epstein Secrets

ion only on a matter that is not in dispute"). 159 Cassell, Proposed Amendments, supra note 4, at 868. 160 Proposed Amendments, supra note 71. 161 U.S. Dep't of Justice, Office for Victims of Crime, Attorney General Guidelines for Victim and Witness Assistance 30 (2005) (defining what can be considered in determining

lose the identity of its witnesses before trial. However, the basis for such grants of authority now seems defunct. For instance, in United States v. Armstrong, the Ninth Circuit recognized no authority exists in the federal rules for requiring the government to disclose the names of its witnesses. 74 Still,

disclosure of witness names before trial appears inconsistent with the federal rules. And even if the Ninth Circuit's approach was valid at the time Armstrong was decided, such an approach is no longer valid in light of the CVRA. Rule 57(b) only provides a basis for court authority in the absence of control

97 U.S. 358, 364 (1970) (holding that proof beyond a reasonable doubt is constitutionally required under the Due Process Clause). ° United States v. Armstrong, 517 U.S. 456, 456-71 (1996) (examining selective prosecution claim based on racial bias); see also Whren v. United States, 517 U.S. 806, 813 (1996)

: Room for Debate (Apr. 9, 2015), hittps://www.nytimes.com/roomfordebate/2015/04/09/are -police-too-quick-to-use-force. 32 See Michael Planty et al, U.S. Dep't of Justice, Female Victims of Sexual Violence, 1994-2010, at 6 (2013), hittps://www.bjs.gov/content/pub/pd{/{vsv9410.pdf (estimating portion of sexual assaults

nesses),; Pub L. No. 101-647, 104 Stat. 4789 (1990). 35 Victim and Witness Protection Act, Pub. L. No. 97-291, 6(a), 96 Stat. 1248, 1252 (1982). 36 U.S. Dep't of Justice, Office of the Att'y Gen., Attorney General Guidelines for Victim and Witness Assistance (1995). 37 Td. 38 U.S. Dep't of Justice, Office of the Att'

246 150 Cong. Rec. $10,911 (daily ed. Oct. 9, 2004) (statement of Sen. Kyl) (emphases added). 247 Fuentes v. Shevin, 407 U.S. 67, 80 (1972) (quoting Armstrong v. Manzo, 380 U.S. 545, 552 (1965)). 248 150 Cong. Rec. $4264 (daily ed. Apr. 22, 2004) (statement of Sen. Kyl) (emphasis added). 249 See 18 U.S.C.