Epstein Secrets

re Acker, 596 F.3d 370, 373 (6th Cir. 2010). The district courts that have considered the question are divided. Compare, e.g., 1' United States it Oakum, No. 3:08CR132, 2009 WL 790042, at *2 (E.D. Va. Mar. 24, 2009) (holding that CVRA rights can attach prior to the commencement of criminal proceedi

speedy trial right "may attach before an indictment and as early as the time of arrest and holding to answer a criminal charge." ) United States v. Gouveia 467 U.S. 180, 190, 104 S. Ct. 2292, 2298, 81 L.Ed.2d 146 (1984). 18 The Majority argues: "Although it's true, at least in the abstract, that the te

fore charges were filed but were subject to the outer limit that the Government has at least “contemplated” charges.” Similarly, in United States v. Oakum,” the District Court for the Easter District of Virginia considered a claim that CVRA nghts did not apply until after a defendant had been convicted.

? More importantly for purposes of this Article, the cases holding Tl See 18 U.S.C. § 3771 (e) (2012). 7 U.S. Const. amend. VI. ® United States v. Gouveia, 467 U.S. 180, 190 (1984) (quoting United States v. MacDonald, 456 U.S. 1, 6-7 (1982)) (internal quotation marks omitted). 4 See, e.g., Texas v. Cob

re charges were filed but were subject to the outer limit that the Government has at least "contemplated" charges. 7! Similarly, in United States v. Oakum, ” the District Court for the Eastern District of Virginia considered a claim that CVRA rights did not apply until after a defendant had been convict

ion phase and an earlier investigative phase when "no prosecution is under way." !8° Senator Kyl, for 72 U.S. Const. amend. VI. 73 United States v. Gouveia, 467 U.S. 180, 190 (1984) (quoting United States v. MacDonald, 456 U.S. 1, 6-7 (1982)) (internal quotation marks omitted). ™ See, e.g., Texas v. Cob