Epstein Secrets

in Dean has been cited in one very recent District Court decision, which provides further support for Petitioner's position here. In United States' Rubin, 20(8 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

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).?

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

on May 30, 2008 (Ex. 5). 4. Throughout the investigation, the Fill 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 arc 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. I ). Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she was interviewed (Ex. 2).

ly compromising its ability to be impartial to the government and defendant, the only true parties to the trial of the indictment" United States v. Rubin, 558 F. Supp. 2d 411, 428 (E.D.N.Y. 2008). 4 EFTA00230133 1 .i i r- ate': , Case 9:08-cv-80736-KAM Document 58 Entered on FLSD Docket 04/07/2011

to provide information supporting whatever claim a victim may wish to assert in a motion for relief under section 3771(d)(3). In United States v. Rubin, 558 F.Supp.2d 411 (ED.N.Y. 2008), an alleged victim of a stock swindle claimed the right to confer in section 3771(aX5) included a right to obtain

r victims [including C.W.J were contacted and these provisions were discussed' (emphasis added). Similarly at page 5, the declaration states: "After C.W. had been notified of the terms of the agreement " (emphasis added). I write to inquire whether, in view of the fact that the provision noted above

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

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

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 C'VRA. After citing Dean, the District Court agreed that

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

lly compromising its ability to be impartial to the government and defendant, the only true parties to the trial of the indictment" United States'. Rubin, 558 F. Supp. 2d 411, 428 (E.D.N.Y. 2008). 4 08-80736-CV-MARRA 000887 EFTA00230711 1 .i i r- ate': , Case 9:08-cv-80736-KAM Document 58 Entere

r victims [including C.W.] were contacted and these provisions were discussed' (emphasis added). Similarly at page 5, the declaration states: "After C.W. had been notified of the terms of the agreement " (emphasis added). I write to inquire whether, in view of the fact that the provision noted above