Epstein Secrets

apply not only to references to unindicted co-conspirators in indictments and factual proffers, but also to motion papers. See, e.g., United States" Anderson, 55 F. Supp. 2d 1163, 1168 (D. Kan. 1999) ("After carefully reviewing the government's moving papers on the conflict of interest jssuc, the court c

llowed those other victims to participate while maintaining some semblance of privacy. Petitioners also reiterate baseless allegations made against AUSA Villafaila regarding the choice of the attorney-representative for the victims, despite knowing that: (1) the issue of the attorney-representative arose after

e process because the litigants and the courts assume that the sole purpose of discovery is to assist trial preparation.") (quoting United States'. Anderson, 799 F.2d 1438, 1441(11'h Cir. 1986; emphasis in original). See also Anderson, 799 F.2d at 1441 ("Historically, discovery materials were not availa

ie Villafana secured pro bono counsel to represent Jane Doe #1. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafaila secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Le

r disputes. Construing the CVRA in the way that "See 18 U.S.C. § 113 (assault within territorial jurisdiction of the United States); United States. Anderson, 528 F.2d 590, 591 (5th Cir. 1976) (in prosecution for assault with intent to commit murder within territorial jurisdiction of United States, distri

tters in approximately June 2007 [Jane Doe #1] and August 2006 [Jane Doe #2) wherein they were advised of this right and given the phone numbers of AUSA Villafaila, FBI Special Agent Kuyrkendall, and the Justice Department's Office for Victims of Crime. The letters specifically advised that if the Petitioners