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(S.D.N.Y. 2005) has been a party to lawsuits in the South- ern District of New York, both as a plain- tiff and defendant.
sal connection be- tween the conduct and the injury; and (4) severe emotional distress.” Stuto v. Fle- ishman, 164 F.3d 820, 827 2d Cir.1999) (citing Howell v. New York Post Co. 81 N.Y.2d 115, 121, 596 N.Y.S.2d 350, 612 N.E.2d 699 (1998)). “ ‘Liability has been found only where the conduct has been so out
Page: HOUSE_OVERSIGHT_017895 →Article: Criminal Enforcement Redundancy: Oversight of Decisions Not to Prosecute
f counsel to indigent state criminal defendants); Powell v. Alabama, 287 U.S. 45, 53 (1932) (holding defen
onvincing Congress to expand their discretion at the expense of judges' sentencing authority, see United States v. Kupa, 976 F. Supp. 2d 417, 419-27 (E.D.N.Y. 2013) (describing the legislative history and Justice Department lobbying related to federal drug statutes, notably 27 U.S.C. § 841 (2012)). 218 See
Page: HOUSE_OVERSIGHT_016549 →ARTICLE: Recognizing Victims in the Federal Rules of Criminal Procedure: Proposed Amendments in Light of the Crime Victims' Rights Act
2, 2004) (statement of Sen. Kyl). 311 See, e.g., Powell v. Alabama, 287 U.S. 45, 73 (1932) (holding, in a
rious crimes the right to restitution. *°* Reinforcing those laws, the CVRA guarantees that victims have "the right 43 Magistrate Judge Orenstein of the Eastern District of New York, who has written many thoughtful opinions on the CVRA, has taken a contrary position. See Report and Recommendation, United States v. Ingrassis, No.
Page: HOUSE_OVERSIGHT_017749 →Entities connected to both Howell and District Court for the Southern District of New York

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Donald Trump
PERSON
Audrey Strauss
PERSON
Marc Rich
PERSON
Bill Clinton
PERSON
Julie K. Brown
PERSONFBI
ORGANIZATION
Virginia Giuffre
PERSON
Geoffrey S. Berman
PERSONJane Doe
PERSON
Michael Cohen
PERSON
George W. Bush
PERSON
Joe Biden
PERSONEmmy Taylor
PERSON
Bradley Edwards
PERSON
Stephen Hawking
PERSON