Epstein Secrets

onal basis for precluding trial of criminal case by injunction. Melvin L. Klafter, Leonard R. Harten- feld, Chicago, Ill., for appellant. Edward,. Hanrahan, U. S. Atty., John Peter Lulinski, Thomas W. James, Asst. U. S. Attys., Chicago, Ill., William W. Goodrich, Asst. Gen. Counsel, Joanne S. Sisk. A

ers, Inc., Petitioners-Ap- pellees, v. UNITED STATES of America, Respondent-Appellant. No. 474, Docket 95-6119. United States Court of Appeals, Second Circuit. Argued Aug. 81, 1996. Decided Oct. 17, 1996. Government appealed from order en- tered in the United States District Court for the Eastern Distri

stead, the courts simply cited to language from a Second Circuit decision that stated that the CVRA does not give

bstantive discussion of whether CVRA rights apply in criminal cases before the filing of charges. Instead, the courts simply cited to language from a Second Circuit decision that stated that the CVRA does not give victims any rights against defendants until those defendants have been convicted'!’—a holding clearl

t grant victims any rights against individuals who have not been convicted of a crime.”” (quoting In re W.R. Huff Asset Mgmt. Co., 409 F.3d 555, 564 (2d Cir. 2005))). '3 Of course, a defendant cannot be ordered to pay restitution as part of his sentence until he has been found guilty. See 18 U.S.C. § 3664

stead, the courts simply cited to language from a Second Circuit decision that stated that the CVRA does not give

"the CVRA does not grant victims any rights against individuals who have not been convicted of a crime. W.R. Huff Asset Mgmt. Co., 409 F.3d 555, 564 (2d Cir. 2005))). (quoting Jn re 3 Of course, a defendant cannot be ordered to pay restitution as part of his sentence until he has been found guilty. See /

bstantive discussion of whether CVRA rights apply in criminal cases before the filing of charges. Instead, the courts simply cited to language from a Second Circuit decision that stated that the CVRA does not give victims any rights against defendants until those defendants have been convicted !!* - a holding cle

, 689 (1972)). 76 See, e.g., United States v. Alvarado, 440 F.3d 191, 196 (4th Cir. 2006). ” 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. Cir. 1965)); see Wayne R. LaFave et al., Criminal Procedure § 6.4(e), at 670 (3d ed. 2007) ("There is a

ra Lyn Bassett, Recusal and the Supreme Court, 56 Hastings L.J_ 657, 678-79 (2005) (citing United States v. Will, 449 U.S. 200, 211-12 & n.12 (1980); Hanrahan v. Hampton, 446 U.S. 1301, 1301 (1980)). 255 Model R. Prof] Conduct 4.4(a) (2007); see also ABA Criminal Justice Study, Standard 4-4.3 (1993). 256

ongressional determination, blocking defense efforts to obtain pretrial discovery about government witnesses. For example, in United States v. Coppa, the Second Circuit overturned the district court's approval of a scheduling order requiring the government to identify its witnesses in advance of trial. +3? The distri