Epstein Secrets

v. Valerio, 9 F. Supp. 3d 283, 292 (E.D.N.Y. 2014) (Bianco, J.) (collecting cases). The Second Circuit has never directly addressed this issue. See United States v. Sabhnani, 493 F.3d 63, 78 n.18 (2d Cir. 2007) ("The government has not argued and, therefore, EFTA00030252 --- PAGE BREAK --- Honorable Richard M

Kazeem, No. 15 Cr. 172, 2015 WL 4645357, at *3 (D. Or. Aug. 3, 2015); United States v. Young, Nos. 12 Cr. 502, 12 Cr. 645, 2013 WL 12131300, at *7 (D. Utah Aug. 27, 2013); United States v. Cohen, No. C 10-00547, 2010 WL 5387757, at *9 n. I I (N.D. Cal. Dec. 20, 2010); United States v. Bohn, 330 F. Supp.

6, 1998, at BS. 22 Victims' Rights Amendment. Hearing on S.J. Res. 6 Before the S. Judiciary Comm., 105th Cong. 64 (1997) (statement of Janet Reno, U.S. Att'y Gen.). 30 See www.nveap.org (last visted Dec. 30, 2007). 3! For a comprehensive history of victims' efforts to pass a constitutional amendment,

able to reflect the new role of victims throughout the Rules. Moreover, Congress intended the CVRA to be "a formula for success" and a "model for our States." + The only way the federal rules could serve as a model, I argued, was by fully implementing victims’ rights. I then proposed twenty-eight specific

to interpret CVRA); United States v. Cienfuegos, 462 F.3d 1160, 1165 (9th Cir. 2006) (same); United States v. Degenhardt, 405 F. Supp. 2d 1341, 1344 (D. Utah 2006) (same); United States v. Ingrassia, 2005 WE 2875220 (E.D.N_Y. 2005) (same). 94 28 U.S.C. § 2072(b) (2006). °° CVRA Subcommittee Memo, supra n

gly expects this to happen. Congress adopted the CVRA with the express goal of making the new law "a formula [*855] for success" and a "model for our States." 111 Congress clearly wants the new law aggressively implemented, thereby avoiding the need for further legislative action or even, possibly, a fede

thdrawn if the CVRA was passed). 224 18 U.S.C. 3663A, 3664 (2000). 25 Td. 3663, 3664. See generally United States v. Bedonie, 317 F. Supp. 2d 1285 (D. Utah 2004) (discussing different statutes), rev'd on other grounds, United States v. Serawop, 410 F.3d 656 (10th Cir. 2005). 26 18 U.S.C. 3663A(a)(1) (em

interests of justice standard); United States v. Charmer Indus., Inc., 711] F.2d 1164, 1174 (2d Cir. 1983) (compelling need standard). 68 See, e.g., D. Utah Crim. Local R. 32-1(c) (presentence reports not released without order of the court). DAVID SCHOEN HOUSE_OVERSIGHT_017751 --- PAGE BREAK --- Page

p this [i.e., the NPA] from becoming public." (DE 407 at ¶ 37.) On September 24, 2007, Epstein and the Office formally reached an agreement whereby the United States would defer federal prosecution in favor of prosecution by the State of Florida. Epstein and the Office accordingly entered into a NPA reflecting su

pe of communication between prosecutors and victims that was intended by the passage of the CVRA. See United States v. Heaton 458 F. Supp. 2d 1271 (D. Utah 2006)(government motion to dismiss charge of using facility of interstate commerce to entice minors to engage in unlawful sexual activity would not

ein was within his rights to attempt to persuade higher authorities within the Department of Justice to overrule the prosecutorial decisions of the U. S. Attorney's Office in the Southern District of Florida, the CVRA was designed to give the victims the same opportunity to attempt to affect prosecuto

p this [i.e., the NPA] from becoming public." (DE 407 at 1137.) On September 24, 2007, Epstein and the Office formally reached an agreement whereby the United States would defer federal prosecution in favor of prosecution by the State of Florida. Epstein and the Office accordingly entered into a NPA reflecting su

pe of communication between prosecutors and victims that was intended by the passage of the CVRA. See United States v. Heaton 458 F. Supp. 2d 1271 (D. Utah 2006)(government motion to dismiss charge of using facility of interstate commerce to entice minors to engage in unlawful sexual activity would not