Epstein Secrets

easonable efforts with a goal of providing victims with a meaningful opportunity to offer their views before a plea agreement is formally reached." U.S. Department of Justice, Attorney General Guidelines for Victim and Witness Assistance 41 (2012), available at https:// www.justice.govisites/defaultifiles/olp/docs/agguide

or sentencing proceeding the government's understanding of the amount of possible restitution based upon consultation with, inter alia, the victim." D. Conn. L. Crim. R. 32(m). Victims do not know the ins•and•outs of the restitution statutes. Prosecutors should. The Government's pre-plea consultation wit

Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 20

Dec. 20, 2010); United States v. Bohn, 330 F. Supp. 2d 960, 961 (W.D. Tenn. 2004); United States v. Stroh, No. 396 Cr. 139, 2000 WL 1832956, at *5 (D. Conn. Nov. 3, 2000); United States v. Botero, 604 F. Supp. 1028, 1035 (S.D. Fla. 1985). . The Department of Justice's Office of International Affairs is

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ars to be somewhat sparse— perhaps because few defendants attempt such a maneuver—see United States v. Calderon, 15 Cr. 025, 2017 WL 6453344, at *3 (D. Conn. Dec. I, 2017) (discussing the relative lack of specific guidance in the context of an application to modify protective orders in criminal cases), se

e identities of .. . victims so that other victims will not be deterred from reporting such crimes." United States v. Paris, 2007 WL 1484974, at *2 (D. Conn. May 18, 2007). Moreover, and consistent with those interests, courts in this Circuit have routinely acknowledged the need to protect victim-witness

ject to a wide range of restrictions, including Rule 6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and other policies of the Department of Justice and the U.S. Attorney's Office for the Southern District of New York. In this case, consistent with the Government's customary practice, and as the

Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 20

Dec. 20, 2010); United States v. Bohn, 330 F. Supp. 2d 960, 961 (W.D. Tenn. 2004); United States v. Stroh, No. 396 Cr. 139, 2000 WL 1832956, at *5 (D. Conn. Nov. 3, 2000); United States v. Botero, 604 F. Supp. 1028, 1035 (S.D. Fla. 1985). . The Department of Justice's Office of International Affairs is