Epstein Secrets

ment deemed was a "reasonable procedure to give effect to this chapter that does not unduly complicate or prolong the proceedings." United States v. BP Products North America, Inc., 2008 WL 501321 (S.D.Tex. Feb. 21, 2008) at * 2. The government announced to the court 29 Respondent's Exhibit A Case No. 08-80736-CIV-MARR

ormally lodged against an accused, in determining whether an individual was covered by the CVRA. In In Re Stewart, 552 F.3d 1285 (I Iih Cir. 2008), the Eleventh Circuit observed, in the opening "The Justice for All Act included the CVRA and several other criminal laws. 24 Respondent's Exhibit A Case No. 08-80736-

prelude to the full unfettered exercise of their conferral rights at a time that will enable the victims to exercise those rights meaningfully. See BP Products North America, supra at *14 ("Section 3771(c)(1) requires government officials to use best efforts to give victims notice of their rights under subsection (1), i

The CVRA at §3771(e) defines a "crime victim" as " a person directly and proximately harmed as a result of the commission of a Federal offense." In the Eleventh Circuit, a two-part test is employed to determine whether an individual qualifies as a crime victim under this statute: First, the court must identify the

ment deemed was a "reasonable procedure to give effect to this chapter that does not unduly complicate or prolong the proceedings." United States v. BP Products North America, Inc., 2008 WL 501321 (S.D.Tex. Feb. 21, 2008) at * 2. The government announced to the court 29 EFTA00078863 Case 9:08-cv-80736-KAM Document 62

ormally lodged against an accused, in determining whether an individual was covered by the CVRA. In In Re Stewart, 552 F.3d 1285 (I 1ih Cir. 2008), the Eleventh Circuit observed, in the opening "The Justice for All Act included the CVRA and several other criminal laws. 24 EFTA00078858 Case 9:08-cv-80736-KAM Docu

ictims a right to approve or disapprove a proposed plea in advance or to participate in plea negotiations." In re Dean on remand as United States'. BP Products North America, Mc., 610 F. Supp. 2d 655, 727 (S.D. Tex. 2009). Instead, "[t]he purpose of the reasonable right to confer is for victims to provide information to

pen exchange of information to promote significant private and public interests. They arc: the decision of Judge Marcus, before he was appointed to the Eleventh Circuit, denying discovery and recognizing a privilege for airline pilots who report incidents and violations, In Re Air Crash Near Cali, Colombia, 959 F.

sing its broad discretion." a at 395. In pear, the government sought and obtained an eK pane order permitting it to negotiate a plea agreement with BP Products North America, without first consulting with the victims, individuals injured and survivors of those killed in a refinery explosion. A plea agreement was ultimat

njoin the stay. And we conclude that this provision does not violate separation of powers principles.") (emphasis added). One District Court within the Eleventh Circuit recently construed "the plain language of § 3509(k)" as "requirlind a stay in a case . . . where . . . a parallel criminal action [is] pending." Do

ment deemed was a "reasonable procedure to give effect to this chapter that does not unduly complicate or prolong the proceedings." United States v. BP Products North America, Inc., 2008 WL 501321 (S.D.Tex. Feb. 21, 2008) at " 2. The government announced to the court 29 EFTA00230094 Case 9:08-cv-80736-KAM Document 62

Jersey. I am also admitted to the practice in the United States District Court for the Southern District of Florida, the U.S. Court of Appeals for the Eleventh Circuit, the U.S. Supreme Court, and several other federal courts. 3. I graduated from Princeton University in 1984 with a B.S.E. in civil engineering cu