Epstein Secrets

83, 86 (1963) (holding prosecution's withholding of the confession of defendant's confederate violated defendant's due process rights). 7 Gideon v. Wainwright, 372 U.S. 335, 342 (1963) (extending Sixth Amendment right to assistance of counsel to indigent state criminal defendants); Powell v. Alabama, 287 U.

ublic Prosecutions Act 1983 s 10(2) (Austl.) (preserving private prosecution); id. s 9(5) (giving the Director power to take over a prosecution for a Commonwealth offence that has been instituted by another and either carry on or discontinue it); Annual Report 2014-15, Commonwealth Dir. Pub. Prosecutions (2015)

e first states to prohibit privately funded prosecutors even under supervision of public prosecutors were Massachusetts, Michigan, and Wisconsin. See Commonwealth v. Gibbs, 70 Mass. (4 Gray) 146, 147-48 (1855); Meister v. People, 31 Mich. 99, 104-06 (1875); Biemel v. State, 37 N.W.244, 248-49 (Wis. 1888). See a

ft. Rape victims requested the return of their records from the center and, in some cases, even requested termination of the counseling relationship. Commonwealth v. Wilson, 602 A.2d 1290, 1294 n.6 (Pa. 1992); Tera Jckowski Peterson, Comment, Distrust and Discovery: The Impending Debacle in Discovery of Rape Vi

ermits the court in both civil and criminal cases to "request an attorney to represent any person unable to afford counsel." 49° And before Gideon v. Wainwright, *°° courts could request 45 Td. 46 Td. 47 Tn possible response to such concerns as I raise here, the Advisory Committee modified the Advisory Comm

rel. Romley v. Superior Courts, 836 P.2d 445, 451-52 (Ariz. Ct. App. 1992) (crime victim had the right to deny defendant access to medical records); Commonwealth v. Wilson, 602 A.2d 1290, 1296-97 (Pa. 1992). See generally Tera Jckowski Peterson, Distrust and Discovery: The Impending Debacle in Discovery of Rap

nd criminal cases. 3!! While these cases do not directly involve [*913] appointment of counsel for crime victims, their principles 309 Cf. Gideon v. Wainwright, 372 U.S. 335, 344 (1963) (discussing "fairness" to the defendant as a reason for recognizing a right to appointed counsel). 310 150 Cong. Rec. S426