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lity." Dolliver, James, "Victims' Rights Constitutional Amendment: A Bad Idea Whose Time Should Not Come," 34 Wayne L. Rev. 87, 90 (1987) (quoted in Levine, Danielle, "Public Wrongs and Private Rights: Limiting the Victim's Role in a System of Public Prosecution," 104 Nw. U. L. Rev. 335, 353 (2010)).
A Case No. 08-80736-CIV-MARRA/JOHNSON EFTA00208063 Case 9:08-cv-80736-KAM Document 57-1 Entered on FLSD Docket 04/07/2011 Page 28 of 54 In Re Rendon Galvis, 564 F.3d 170, 175 (2n° Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the c
ity." Dolliver, James, "Victims' Rights Constitutional Amendment: A Bad Idea Whose Time Should Not Come," 34 Wayne L. Rev. 87, 90 (1987) (quoted in Levine, Danielle, "Public Wrongs and Private Rights: Limiting the Victim's Role in a System of Public Prosecution," 104 Nw. U. L. Rev. 335, 353 (2010)). E
ment that a victim be "directly and proximately harmed" encompassed the traditional "but for" and proximate cause analyses. Id. at 350, citing In Re Rendon Galvis , 564 F.3d 170, 175 (2 ' Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the
lity." Dolliver, James, "Victims' Rights Constitutional Amendment: A Bad Idea Whose Time Should Not Come," 34 Wayne L. Rev. 87, 90 (1987) (quoted in Levine, Danielle, "Public Wrongs and Private Rights: Limiting the Victim's Role in a System of Public Prosecution," 104 Nw. U. L. Rev. 335, 353 (2010)).
mate cause analyses. Id. at 350, citing 27 EFTA00078861 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 28 of 54 In Re Rendon Galvis, 564 F.3d 170, 175 (2nd Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the c
lity." Dolliver, James, "Victims' Rights Constitutional Amendment: A Bad Idea Whose Time Should Not Come," 34 Wayne L. Rev. 87, 90 (1987) (quoted in Levine, Danielle, "Public Wrongs and Private Rights: Limiting the Victim's Role in a System of Public Prosecution," 104 Nw. U. L. Rev. 335, 353 (2010)).
ate cause analyses. Id. at 350, citing 27 EFTA00177077 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 28 of 54 In Re Rendon Galvis, 564 F.3d 170, 175 (20° Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the
ality." Dolliver, James, "Victims' Rights Constitutional Amendment A Bad Idea Whose Time Should Not Come," 34 Wayne L. Rev. 87, 90 (1987) (quoted in Levine, Danielle, "Public Wrongs and Private Rights: Limiting the Victim's Role in a System of Public Prosecution," 104 Nw. U. L. Rev. 335, 353 (2010)).
, citing 27 EFTA00230092 ff ell.;;;;;:t; --- ------- 1 Case 9:O8-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 28 of 54 In Re Rendon Galvis, 564 F.3d 170, 175 (2gd Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the c
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