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and a federal prosecution and trial ensued, see Villafana Declaration, Dkt. 14 at pgs. 4-5 ("the agents and
the CVRA because "the offense charged against a defendant can serve as a basis for identifying a 'crime victim' as defined in the CVRA"); Searcy v. Paletz, No. 6:07-1389-GRA-WMC, 2007 WL 1875802 *6 . June 27, 2007) (inmate does not qualify as a "crime victim" under the CVRA wher, has been a prosecut
residences, his criminal conduct had occurred in other locations; or whether the additional victims might implicate other offenders. In addition, Villafaña planned to approach the female assistants to attempt to obtain cooperation, but that step had not been taken.252 Most importantly, Acosta ended t
e described unless there is an appropriate, articulable reason not to do so.” Id., Art. II, ¶ C. 399 Id., Art. IV, ¶ B.1. 400 Searcy v. Paletz, 2007 WL 1875802, at *5 (D.S.C. June 27, 2007) (an inmate is not considered a crime victim for purposes of the CVRA until the government has filed c
CRIMINAL LAW: CRIME VICTIMS' RIGHTS DURING CRIMINAL INVESTIGATIONS? APPLYING THE CRIME VICTIMS' RIGHTS ACT BEFORE CRIMINAL CHARGES ARE FILED
ctim of uncharged conduct should not be afforded statutory protections. !°! Yet none of these cases - United States v. 10 104 Turner, !9? Searcy v. Paletz, !°3 or Searcy v. Skinner - provide strong support for OLC's position. Turner is a particularly 9 See 42 U.S.C. § 10607(c). % Td. § 10607(c)(3)(A).
Page: HOUSE_OVERSIGHT_017616 →(1), (5), (8), (c)(1) (2012). 213 See 42 U.S.C. § 10607(c)(2) (2006). 214 See Attorney General Guidelines, supra note 52, at 41-42. 215 Letter from A. Marie Villafana, Assistant U.S. Att'y, to Jane Doe #1 (June 7, 2007), reprinted in Jane Doe Motion, supra note 40, at ex. C. 216 Td, 217 Td, 218 See Victims' Right
Page: HOUSE_OVERSIGHT_017630 →upra note 52, at 41-42. 215 Letter from A. Marie Villafana, Assistant U.S. Att'y, to Jane Doe #1 (June 7, 20
Page: HOUSE_OVERSIGHT_017630 →Crime Victims' Rights During Criminal Investigations? Applying the Crime Victims' Rights Act Before Criminal Charges Are Filed
ded that a victim of uncharged conduct should not be afforded statutory protections.'°! Yet none of these cases—United States v. Turner,'°? Searcy v. Paletz,'® or Searcy v. Skinner'°*—provide strong support for OLC’s position. Turner is a particularly poor fit. Although OLC’s memorandum characterizes Turn
Page: HOUSE_OVERSIGHT_014057 →in state criminal justice systems. Nearly two-thirds of states have adopted constitutional provisions to protect victims throughout 715 Letter from A. Marie Villafafia, Assistant U.S. Att’y, to Jane Doe #1 (June 7, 2007), reprinted in Jane Doe Motion, supra note 40, at ex. C. HOUSE_OVERSIGHT_014076 --- PAGE BREAK
Page: HOUSE_OVERSIGHT_014077 →Entities connected to both A. Marie Villafana and Paletz

Jeffrey Epstein
PERSON
Alexander Acosta
PERSON
Bradley Edwards
PERSONJane Doe
PERSONLeon Black
PERSON
United States
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Paul Cassell
PERSONMaria Farmer
PERSON
Ken Starr
PERSON
Bill Clinton
PERSON
Salt Lake City
LOCATION
the University of Utah
ORGANIZATIONScott Rothstein
PERSON
S.J. Quinney College of Law
ORGANIZATION
Michael Reiter
PERSON
Jay Howell
PERSONCriminal Division
ORGANIZATION
Mark Filip
PERSON