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llow 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 under the facts of this case. C. The U.S. Attorney's Office Has Previous
oner, she would have explained why this proposed disposition did not begin to reflect "the seriousness of the offense " 18 U.S.C. § 3553(a)(2)(A). The Eleventh Circuit has instructed that the district courts must make substantial findings before sealing records in cases before it. For instance, in United States v.
tion "sexual intercourse for hire" where the West Virginia statues also lacked a definition. Prince , 515 F
. The statute does not define "facility or means of interstate commerce" or "prostitution." 1. A telephone is a "facility of interstate commerce." The Eleventh Circuit, however, has ruled that evidence of the use of a cellular telephone satisfies the element of using a facility or means of interstate commerce. Unit
tion "sexual intercourse for hire" where the West Virginia statues also lacked a definition. Prince , 515 F
. The statute does not define "facility or means of interstate commerce" or "prostitution." 1. A telephone is a "facility of interstate commerce." The Eleventh Circuit, however, has ruled that evidence of the use of a cellular telephone satisfies the element of using a facility or means of interstate commerce. Unit
ru P-009271 File folder entitled "[Victim name]/Jane Doe #3" containing meta-analysis of all phone, travel,
be negated because the Government's communications facilitated "misconduct" by depriving the victims of their rights under the CVRA. (DE 265 at 6). The Eleventh Circuit has recognized that "[t]he crime-fraud exception presents one of the rare and extraordinary circumstances in which 15 EFTA00086459 Case 9:08-cv-
Entities connected to both Virginia Giuffre and The Eleventh Circuit

Jeffrey Epstein
PERSON
Prince Andrew
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Ghislaine Maxwell
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Donald Trump
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSON
United States
LOCATION
Alan Dershowitz
PERSONLeon Black
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Bradley Edwards
PERSONJane Doe
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Bill Clinton
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Julie K. Brown
PERSONthe Southern District
LOCATION
Marc Rich
PERSONMaria Farmer
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Kenneth Marra
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Scarlett Johansson
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Paul Cassell
PERSONFBI
ORGANIZATION