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ictims with a fair amount of skepticism, and noted that the government believed that the victims were trying to use the CVRA as a mechanism to "undo Rubin's guilty plea in exchange for a favorable settlement of their ongoing civil suit in California state court. Movants take vigorous exception to any
that the victims were attempting to use the CVRA to obtain discovery from the defendant. Id. at 416, 425. With respect to certain CVRA rights, the Rubin court noted the lack of a remedy: The CVRA also lists among the rights secured to a victim the right to "be treated with fairness and with respect
(E.D.Va. 2009). Accordingly, rather than create a split of authority, this Court should follow the Fifth Circuit's holding in Dean (and the view of the U.S. District Courts for the Eastern District of New York and the Eastern District of Virginia) and conclude that the CVRA extends rights to Jane Doe #1 and Jane Doe #2
has been cited favorably in two recent District Court decisions, which provides further support for Petitioner's position here. In United States v. Rubin, 2008 WL 2358591 (E.D.N.Y. 2008), the victims argued for extremely broad rights under the CVRA. After citing Dean, the District Court agreed that th
§ 3771(a)(4)." Accordingly, rather than create a split of authority, this Court should follow the Fifth Circuit's holding in Dean (and the view of the U.S. District Courts for the Eastern District of New York and the Eastern District of Virginia) and conclude that the CVRA extends rights to Jane Doe #1 and Jane Doe #2
has been cited favorably in two recent District Court decisions, which provides further support for Petitioner's position here. In United States v. Rubin, 2008 WL 2358591 (E.D.N.Y. 2008), the victims argued for extremely broad rights under 29 EFTA00208402 Case 9:08-cv-80736-KAM Document 48 Entered
(E.D.Va. 2009). Accordingly, rather than create a split of authority, this Court should follow the Fifth Circuit's holding in Dean (and the view of the U.S. District Courts for the Eastern District of New York and the Eastern District of Virginia) and conclude that the CVRA extends rights to Jane Doe #1 and Jane Doe #2
n Dean has been cited in one very recent District Court decision, which provides further support for Petitioner's position here. In United States v. Rubin, 2008 WI. 2358591 (E.D.N.Y. 2008), the victims argued for extremely broad rights under the CVRA. After citing Dean, the District Court agreed that
(E.D.Va. 2009). Accordingly, rather than create a split of authority, this Court should follow the Fifth Circuit's holding in Dean (and the view of the U.S. District Courts for the Eastern District of New York and the Eastern District of Virginia) and conclude that the CVRA extends rights to Jane Doe #1 and Jane Doe #2
has been cited favorably in two recent District Court decisions, which provides further support for Petitioner's position here. In United States.. Rubin, 2008 WL 2358591 (E.D.N.Y. 2008), the victims argued for extremely broad rights under the CVRA. After citing Dean, the District Court agreed that th
§ 3771(a)(4)." Accordingly, rather than create a split of authority, this Court should follow the Fifth Circuit's holding in Dean (and the view of the U.S. District Courts for the Eastern District of New York and the Eastern District of Virginia) and conclude that the CVRA extends rights to Jane Doe #1 and Jane Doe #2
has been cited favorably in two recent District Court decisions, which provides further support for Petitioner's position here. In United States v. Rubin, 2008 WL 2358591 (E.D.N.Y. 2008), the victims argued for extremely broad rights under 29 EFTA00079021 Case 9:08-cv-80736-KAM Document 48 Entered
(E.D.Va. 2009). Accordingly, rather than create a split of authority, this Court should follow the Fifth Circuit's holding in Dean (and the view of the U.S. District Courts for the Eastern District of New York and the Eastern District of Virginia) and conclude that the CVRA extends rights to Jane Doe #1 and Jane Doc #2
n has been cited favorably in two recent District Court decisions, which provides further support for Petitioner's position here. In United States" Rubin, 2008 WL 2358591 (E.D.N.Y. 2008), the victims argued for extremely broad rights under 29 EFTA00185037 c 91118-awari36-1KAM Illaammend get-413nte
(E.D.Va. 2009). Accordingly, rather than create a split of authority, this Court should follow the Fifth Circuit's holding in Dean (and the view of the U.S. District Courts for the Eastern District of New York and the Eastern District of Virginia) and conclude that the CVRA extends rights to Jane Doe #1 and Jane Doe #2
t 361-63 Entered on FLSD Docket 02/10/2016 Page 19 of 1/1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Rubin where they discussed that very scenario stating there at least has to be criminal charges contemplate by the government before these rights kick i
also am admitted to practice in all courts of the states of Minnesota and Florida, the Eighth, Eleventh, and Federal Circuit Courts of Appeals. and the U.S. District Courts for the Southern District of Florida, the District of Minnesota, and the Northern District of California. My bar admission status in California and
has been cited favorably in two recent District Court decisions, which provides further support for Petitioner's position here. In United States v. Rubin, 2008 WL 2358591 (BD.N.Y. 2008), the victims argued for extremely broad rights under 29 EFTA00229945 , , , , , , , • Case 9:08-cv-80736-KAM D
2 (W.Va. 2009). Accordingly, rather than create a split of authority, this Court should follow the Fifth Circuit's holding in Dean (and the view of the U.S. District Courts for the Eastern District of New York and the Eastern District of Virginia) and conclude that the CVRA extends rights to Jane Doe #1 and Jane Doe #2
has been cited favorably in two recent District Court decisions, which provides further support for Petitioner's position here. In United States I Rubin, 2008 WL 2358591 (E.D.N.Y. 2008), the victims argued for extremely broad rights under 29 08-80736-CV-MARRA 000699 EFTA00230523 , , , , , , ,
2 (W.Va. 2009). Accordingly, rather than create a split of authority, this Court should follow the Fifth Circuit's holding in Dean (and the view of the U.S. District Courts for the Eastern District of New York and the Eastern District of Virginia) and conclude that the CVRA extends rights to Jane Doe #1 and Jane Doe #2
Entities connected to both Rubin and the U.S. District Courts

Jeffrey Epstein
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Donald Trump
PERSONLeon Black
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Prince Andrew
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Marc Rich
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Alexander Acosta
PERSON
United States
LOCATION
George W. Bush
PERSON
Scarlett Johansson
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Department of Justice
ORGANIZATIONJane Doe
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Bradley Edwards
PERSONthe Southern District
LOCATION
Kenneth Marra
PERSONFBI
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Virginia Giuffre
PERSONMaria Farmer
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Ghislaine Maxwell
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Julie K. Brown
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Minnesota
LOCATION