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g its broad discretion." Id. at 395. In Dean, the government sought and obtained an ex parte 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
ent, none of Mr. Edwards' clients had expressed a desire to be consulted prior to the resolution of the federal investigation. Id. In October 2007, C.W. was not represented by counsel. a. y 8. She was given telephonic notice of the agreement, as were three other victims. Id. These four individuals we
ed to the victim by both the FBI Victim-Witness Specialist and AUSA Villafafa. ILI 3. Petitioner's counsel, Brad Edwards, Esq., currently represents C.W., T.M., and S.R. The U.S. Attorney's Office victim notification letter to C.W. was provided by the FBI. and the letter to T.M. was hand-delivered by
g its broad discretion." Id. at 395. In Dean, the government sought and obtained an ex parte 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
ent, none of Mr. Edwards' clients had expressed a desire to be consulted prior to the resolution of the federal investigation. Id. In October 2007, C.W. was not represented by counsel. Id.. $ 8. She was given telephonic notice of the agreement, as were three other victims. Id. These four individuals
were provided to the victim by both the FBI Victim-Witness Specialist and AUSA al 3. Petitioner's counsel, Brad Edwards, Esq., currently represents C.W., T.M., and S.R. The U.S. Attorney's Office victim notification letter to C.W. was provided by the FBI. and the letter to T.M. was hand-delivered by
ng its broad discretion." Id. at 395. In Dean, the government sought and obtained an gh 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
on May 30, 2008 (Ex. 5). 4. Throughout the investigation, the FBI agents, the FBI's Victim-Witness Specialist, and your A ffiant had contact with C.W. and S.R. Attorney Edwards' other client, T.M., was represented by counsel and, accordingly, all contact with T.M. was made through that attorney. T
ss Specialist. Attached hereto are copies of the letters provided to Bradley Edwards' three clients, T.M., C.W., and S.R.' Your Affiant's letter to C.W. was provided by the FBI. (Ex. 1). Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she was interviewed (Ex. 2).?
ng its broad discretion." Id. at 395. In Dean, the government sought and obtained an ex 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
were provided to the victim by both the FBI Victim-Witness Specialist and AUSA a¶ 3. Petitioner's counsel, Brad Edwards, Esq., currently represents C.W., T.M., and S.R. The U.S. Attorney's Office victim notification letter to C.W. was provided by the 1:131. and the letter to T.M. was hand-delivered
, and to S.R. on May 30, 2008. Villafafla Decl., ¶ 3. Throughout the investigation, AUSAInauld the FBI's Victim-Witness Specialist had contact with C.W. ¶ 4. Earlier in the investigation, T.M. was represented by James Eisenberg, E:sq. Consequently, all contact with T.M. was made through Mr. Eisenber
Movants rely on a decision from the Southern District of Texas for the notion that CVRA rights apply prior to any prosecution. In United States v. BP Products North America, Inc., the district court reasoned that because § 3771(d)(3) provided for the assertion of CVRA rights "in the district court in which a defendant
eems to assert that Petitioner was given some sort of notice about tF.e plea agreement about nine months ago. Gov't Response at 7 ("in October 2007, C.W. was not represented by counsel. . . . She was given telephonic notice of the agreement, as were three other to EFTA00210782 Case 9:08-cv-80736-K
g its broad discretion." Id. at 395. In Dean , the government sought and obtained an ex parte 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 ultima
he FBI Victim-Witness Specialist and-. Id. , 1 3. Petitioner's counsel, Brad Edwards, Esq., currently represent The victim notification letter to C.W. was hand-delivered by FBI agents. EFTA00215547 The letter toMwas hand-delivered by to her when she was interviewed in 2007. Throughout the inve
Movants rely on a decision from the Southern District of Texas for the notion that CVRA rights apply prior to any prosecution. In United States v. BP Products North America, Inc., the district court reasoned that because § 3771(d)(3) provided for the assertion of CVRA rights "in the district court in which a defendant
eems to assert that Petitioner was given some sort of notice about tl-e plea agreement about nine months ago. Gov't Response at 7 ("In October 2007, C.W. was not represented by counsel. . . . She was given telephonic notice of the agreement, as were three other 10 EFTA00235258 Case 9:08-cv-80736-K
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
on May 30, 2008 (Ex. 5). 4. Throughout the investigation, the FBI agents, the FBI's Victim-Witness Specialist, and your A (tient had contact with C.W. and II Attorney Edwards' other client, was represented by counsel and, accordingly, all contact with MB was made through that attorney. That attor
Entities connected to both BP Products North America and C.W.

George W. Bush
PERSON
Bradley Edwards
PERSON
A. Marie Villafana
PERSON
Jeffrey Epstein
PERSONT.M.
PERSON
Dexter Lee
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSONJane Doe
PERSONS.R.
PERSONJack Goldberger
PERSONthe Southern District
LOCATION
Scarlett Johansson
PERSONFBI
ORGANIZATION
Department of Justice
ORGANIZATION
United States
LOCATIONJames Eisenberg
PERSON
Bill Richardson
PERSON
Palm Beach Police Department
ORGANIZATION
Southern District of New York
ORGANIZATION