Epstein Secrets

to his counsel outside of the room in which the deposition is being taken). DATED this 11th day of September 2009. Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Flo

A RUDA DAVID VAR.EMA 1FLORIDA 80,',RD CERr1mo CIVIL.TRIAt l.AWY£it ?ADMI.TTED TO PRACTICE IN f.LORJDA AND_ COLORADO Sent by E-mail and U.S. Mail Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Re: Doe v. E_pstein L.M. v. Epstein E.W. v.

se he had not talked to her he had not had “contact.” The law does not take such an absurdly narrow view of what amounts to “contact.” See, e.g., BRYAN A. GARNER, BLACK’S LAW DICTIONARY (8th ed. 2004) (defining “no contact” order as the same as a “stay-away order” and noting that a “stay-away order” usually “

of September 2009. Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTE

RJDA AND_ COLORADO Sent by E-mail and U.S. Mail Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las O

w view of what amounts to “contact.” See, e.g., BRYAN A. GARNER, BLACK’S LAW DICTIONARY (8th ed. 2004) (defining

RGES ARE FILED Winter, 2014 Reporter 104 J. Crim. L. & Criminology 59 * Length: 23898 words Author: PAUL G. CASSELL*, NATHANAEL J. MITCHELL** and BRADLEY J. EDWARDS*** * Ronald N. Boyce Presidential Professor of Criminal Law, S.J. Quinney College of Law at the University of Utah. ** Associate, Snow, Christensen &

CASSELL*, NATHANAEL J. MITCHELL** and BRADLEY J. EDWARDS*** * Ronald N. Boyce Presidential Professor of Cr

l). 40 Does v. United States, 817 F. Supp. 2d 1337 (S.D. Fla. 2011). In the interest of full disclosure, two of the authors of this Article (Cassell and Edwards) are co-counsel for the victims in this case. The statement of the facts in this Article draws heavily on the victims' allegations as they have detai

under the Act even before charges are filed. [*73] C. COURTS RECOGNIZE THAT CRIME VICTIMS HAVE CVRA RIGHTS BEFORE CHARGING 4 See Antonin Scalia & Bryan A. Garner, Reading Law: The Interpretation of Legal Texts 56 (2012). % 18 U.S.C. § 3771(a) (2012) (enumerating eight rights); id. § 3771(c)(1) (requiring gove

tion Paul G. Cassell, Nathanael J. Mitchell, and Bradley J. Edwards, Crime Victims’ Rights During Criminal Investigati

have taken steps to object” to the plea agreement, and that they believed criminal prosecution to be “extremely important”). 4 See ANTONIN SCALIA & BRYAN A. GARNER, READING Law: THE INTERPRETATION OF LEGAL TEXTS 56 (2012). °° 18 U.S.C. § 3771(a) (2012) (enumerating eight rights), id. § 3771(c)(1) (requiring gov