Epstein Secrets

the government's attorney before formal criminal proceedings have commenced. Yet there is no evidence whatsoever that federal prosecutors in Texas, Louisiana, and Mississippi must confer with crime victims before law- enforcement officers "conduct[ ] a raid, seek[ ] a warrant, mak[e] an arrest, interview

t for Sixth Amendment right-to-counsel purposes, that a "prosecution" does not begin with the criminal complaint's filing. See P. United States v. Alvarado, 440 F.3d 191, 199-200 (4th Cir. 2006) ("The filing of a federal criminal complaint does not commence a formal prosecution."); see also, e.g., ‘I

etween misdemeanor and 65 OLC CVRA Rights Memo, supra note 2, at 14 (quoting 18 U.S.C. § 3771(d\(3) (2012)). °° Id. 67 Td. (citing United States v. Alvarado, 440 F.3d 191, 200 (4th Cir. 2006)). 68 Wayne R. LAFAVE ET AL., CRIMINAL PROCEDURE § 1.2(g), at 11 (Sth ed. 2009) (emphasis added). © OLC CVRA Righ

, 172-73 (2001). 1 Brewer v. Williams, 430 U.S. 387, 398 (1977) (quoting Kirby v. Illinois, 406 U.S. 2, 689 (1972)). 1© See, e.g., United States v. Alvarado, 440 F.3d 191, 196 (4th Cir. 2006). 7 OLC CVRA Rights Memo, supra note 2, at 14 n.15 (citing Hanrahan v. United States, 348 F.2d 363, 366 n.6 (D.C.

that implementing such an approach would be difficult.*” Presumably the Justice Department has already been providing such rights in at least Texas, Louisiana, and Mississippi to comply with the Fifth 197 See 18 U.S.C. §§ 2422(b), 2423(b), (e) (2012). 198 A more substantial summary of the case is availabl

442 U.S. 330,339 (1979). 6 OLC CVRA Rights Memo, supra note 2, at 14 (quoting /8 U.S.C. § 3771(d)G) (2012)). 66 Td. 67 Id. (citing United States v. Alvarado, 440 F.3d 191, 200 (4th Cir. 2006)). 68 Wayne R. LaFave et al., Criminal Procedure § 1.2(g), at 11 (5th ed. 2009) (emphasis added). 6° OLC CVRA Rig

on also make clear that a later court hearing would start such a prosecution. For instance, in the Fourth Circuit case cited by OLC, United States v. Alvarado, the court reasons that "the main reason a law enforcement officer files [] a complaint is to establish probable cause for an arrest warrant. The cri

that implementing such an approach would be difficult. 7° Presumably the Justice Department has already been providing such rights in at least Texas, Louisiana, and Mississippi to comply with the Fifth [*95] Circuit's 2008 ruling in In Re Dean, which held that the CVRA extends rights to victims before defen