Epstein Secrets

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

71(b)(1) is inapplicable. There is no role for this Court to fulfill under § 3771(b)(I).s sAs discussed, infra, this interpretation is buttressed by the Federal Rules Committee's decision to incorporate the CVRA into the Federal Rules of Criminal Procedure at Fed. R. Crim. P. 60. 12 Respondent's Exhibit A Case No. 08-8073

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

. Metropolitan Dade County , 932 F.2d 1239, 1243 (11 ih Cir. 1991)(citations omitted). FBAs discussed, infra , this interpretation is buttressed by the Federal Rules Committee's decision to incorporate the CVRA into the Federal Rules of Criminal Procedure at Fed. R. Crim. P. 60. E By making this suggestion, the government i

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

71(b)(1) is inapplicable. There is no role for this Court to fulfill under § 3771(b)(I).s sAs discussed, infra, this interpretation is buttressed by the Federal Rules Committee's decision to incorporate the CVRA into the Federal Rules of Criminal Procedure at Fed. R. Crim. P. 60. 12 EFTA00078846 Case 9:08-cv-80736-KAM Do

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

71(b)(1) is inapplicable. There is no role for this Court to fulfill under § 3771(b)(I).8 8As discussed, infra, this interpretation is buttressed by the Federal Rules Committee's decision to incorporate the CVRA into the Federal Rules of Criminal Procedure at Fed. R. Crim. P. 60. 12 EFTA00177062 Case 9:08-cv-80736-KAM Do

, 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

771(bX1) is inapplicable. There is no role for this Court to fulfill under § 3771(bX1).' sAs discussed, infra, this interpretation is buttressed by the Federal Rules Committee's decision to incorporate the CVRA into the Federal Rules of Criminal Procedure at Fed. R. Crim. P. 60. 12 EFTA00230077 Case 9:08-cv-80736-1(Atvl