Epstein Secrets

(E.D.Va. 2009). Accordingly, rather than create a split of authority, this Court should follow the Fifth Circuit's holding in Dean (and the view of the U.S. District Courts for the Eastern District of New York and the Eastern District of Virginia) and conclude that the CVRA extends rights to Jane Doe #1 and Jane Doc #2

nowledge of the statute and its . . . provisions, and has no expectation of finality in his sentence until the [review by writ] is concluded ...."' LAFAVE ET AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States v. DiFrancesco, 449 U.S. 117, 146 (1980)). 40 EFTA00079032 Case 9:08-cv-80736-

§ 3771(a)(4)." Accordingly, rather than create a split of authority, this Court should follow the Fifth Circuit's holding in Dean (and the view of the U.S. District Courts for the Eastern District of New York and the Eastern District of Virginia) and conclude that the CVRA extends rights to Jane Doe #1 and Jane Doe #2

nowledge of the statute and its . . . provisions, and has no expectation of finality in his sentence until the [review by writ] is concluded ...."' LAFAVE ET AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States v. DiFrancesco, 449 U.S. 117, 146 (1980)). 39 EFTA00207918 reason, it makes se

§ 3771(a)(4)." Accordingly, rather than create a split of authority, this Court should follow the Fifth Circuit's holding in Dean (and the view of the U.S. District Courts for the Eastern District of New York and the Eastern District of Virginia) and conclude that the CVRA extends rights to Jane Doe #1 and Jane Doe #2

nowledge of the statute and its . . . provisions, and has no expectation of finality in his sentence until the [review by writ] is concluded ...."' LAFAVE ET AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States DiFrancesco, 449 U.S. 117, 146 (1980)). 39 EFTA00235789 reason, it makes sense

2 (W.Va. 2009). Accordingly, rather than create a split of authority, this Court should follow the Fifth Circuit's holding in Dean (and the view of the U.S. District Courts for the Eastern District of New York and the Eastern District of Virginia) and conclude that the CVRA extends rights to Jane Doe #1 and Jane Doe #2

knowledge of the statute and its . provisions, and has no expectation of finality in his sentence until the [review by writ] is concluded .. .."' LAFAVE ET AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States I. Dihancesco, 449 U.S. 117,146 (1980)). 40 EFTA00229956 Case 9:08-cv-80736-KA

2 (W.Va. 2009). Accordingly, rather than create a split of authority, this Court should follow the Fifth Circuit's holding in Dean (and the view of the U.S. District Courts for the Eastern District of New York and the Eastern District of Virginia) and conclude that the CVRA extends rights to Jane Doe #1 and Jane Doe #2

knowledge of the statute and its . provisions, and has no expectation of finality in his sentence until the [review by writ] is concluded .. .."' LAFAVE ET AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States Dihancesco, 449 U.S. 117, 146 (1980)). 40 08-80736-CV-MARRA 000710 EFTA0023053