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CRIMINAL LAW: CRIME VICTIMS' RIGHTS DURING CRIMINAL INVESTIGATIONS? APPLYING THE CRIME VICTIMS' RIGHTS ACT BEFORE CRIMINAL CHARGES ARE FILED
the district court in the Does case also rejected Government efforts to dismiss the action. The district court
sented the case to the U.S. Attorney's Office for the Southern District of Florida. In 2007, the Office contacted counsel
ights even before prosecutors filed a superseding indictment covering the specific crimes affecting the victims. Citing Dean, the District Court for the Eastern District of New York agreed that the rights ® John W. Gillis & Douglas E. Beloof, The Next Step for a Maturing Victim Rights Movement: Enforcing Crime Victim Rights in t
Page: HOUSE_OVERSIGHT_017613 →Crime Victims' Rights During Criminal Investigations? Applying the Crime Victims' Rights Act Before Criminal Charges Are Filed
sonable right to confer with the attorney for the Government.” At least in the posture of this case (and we do
esented the case to the U.S. Attomey’s Office for the Southern District of Florida. In 2007, the Office contacted counsel
rights even before prosecutors filed a superseding indictment covering the specific crimes affecting the victims. Citing Dean, the District Court for the Eastern District of New York agreed that the rights were expansive and could apply before charges were filed but were subject to the outer limit that the Government has at least
Page: HOUSE_OVERSIGHT_014053 →onally entered into an agreement with the Federal Government acknowledging that approximately thirty-four (34)
y 2005, the FBI and the U.S. Attorney’s Office in the Southern _ District of Florida learned of Epstein’s repeated sexual a
he summer of 2014, Edwards and Cassell, contacted Government counsel to request their agreement to add two add
s sexual trafficking victims in a case pending in the Southern District of Florida, specifically case no. 08-cv-80736- KA
of a commercial nature whether they belong to the Government or the industrial lend- ing institutions connecte
(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.
DE 1). Generally, they allege that the respondent Government violated their rights under the CVRA by failing t
eclare as follows: 1. Iam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit
Page: HOUSE_OVERSIGHT_014652 →rs, the same standard governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4 GIUFFRE002847 HOUSE_OVERSIGHT_014680
Page: HOUSE_OVERSIGHT_014681 →ARTICLE: Recognizing Victims in the Federal Rules of Criminal Procedure: Proposed Amendments in Light of the Crime Victims' Rights Act
dings," *° to "confer with [the] attorney for the Government n 4l in the case, and to attend court proceedin
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 →ARTICLE: Treating Crime Victims Fairly: Integrating Victims into the Federal Rules of Criminal Procedure
overning information subject to disclosure by the Government in criminal cases, nor any other federal rule or
(9th Cir. 2006); United States v. Degenhardt, 405 F. Supp. 1341, 1343-44 (D. Utah 2005); see also United States v. Turner, 367 F. Supp. 2d 319, 333 (E.D.N.Y. 2005) (reaching same conclusion). *98 Bucklew Memo, supra note 580, app. a, at 299, 302-03. DAVID SCHOEN HOUSE_OVERSIGHT_017711 --- PAGE BREAK --
Page: HOUSE_OVERSIGHT_017712 →Entities connected to both US Government and District Court for the Southern District of New York

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSON
United States
LOCATIONU.S. Attorney's Office
ORGANIZATION
Geoffrey S. Berman
PERSONJane Doe
PERSON
Bill Clinton
PERSON
Donald Trump
PERSONSecond Circuit
ORGANIZATION
Bradley Edwards
PERSONFBI
ORGANIZATION
Paul Cassell
PERSON
U.S. Virgin Islands
LOCATION
Michael Cohen
PERSON
Alexander Acosta
PERSONMartin Weinberg
PERSON
Julie K. Brown
PERSON