Epstein Secrets

earlier pleadings filed in this action, the Government has tried to narrowly construe the CVRA so that it applies only to a "court proceeding." See Gov't Response to Victim's Emergency Petition (doc. #13) at 1-2. The Government's position contravenes the plain language of the CVRA. The CVRA guarantees to Jan

ty 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-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 41 of 42 DATED: March 21,2

earlier pleadings filed in this action, the Government has tried to narrowly construe the CVRA so that it applies only to a "court proceeding." See Gov't Response to Victim's Emergency Petition (doc. #13) at 1-2. The Government's position contravenes the plain language of the CVRA. The CVRA guarantees to Jan

ty 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 sense for the Court to bifurcate the process and determine, first, the extent of the

earlier pleadings filed in this action, the Government has tried to narrowly construe the CVRA so that it applies only to a "court proceeding." See Gov't Response to Victim's Emergency Petition (doc. #13) at 1-2. The Government's position contravenes the plain language of the CVRA. The CVRA guarantees to Jan

y in his sentence until the [review by writ] is concluded ...."' LAFAvs El' AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States v. DiFrancesco, 449 U.S. 117, 146 (1980)). 40 EFTA00208413 Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 41 of 42 DATED: March 21.

e, the Government's lead argument in its response is that there was no "court proceeding" in this case that triggered Petitioner's right to confer. Gov't Response at 1-2. The Government's position flouts the plain language of the CVRA. The CVRA guarantees to Petitioner the right to confer with prosecutors "in

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 EFTA00210829 Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 41 of 42 DATED: March 21.

earlier pleadings filed in this action, the Government has tried to narrowly construe the CVRA so that it applies only to a "court proceeding." See Gov't Response to Victim's Emergency Petition (doc. #13) at 1-2. The Government's position contravenes the plain language of the CVRA. The CVRA guarantees to Jan

ality 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 for the Court to bifurcate the process and determine, first, the extent of the