Epstein Secrets

ties filed briefs on their respective positions. On June 6, 2011, Senator Jon Kyl — the co-sponsor of the CVRA — sent a letter to Attorney General Eric Holder directly stating that he had drafted the CVRA to extend rights to crime victims during the investigative process and expressing his concern that the

he CVRA — sent a letter to Attorney General Eric Holder directly stating that he had drafted the CVRA to

lt with prosecutors "how the case was being handled before being filed in court . . ." Id. (emphasis added). Senator Kyl then went on to explain how the Fifth Circuit had extended rights to crime victims before the formal filing of charges in In re Dean, 527 F.3d 391 (5th Cir. 2008) — a case the victims cite in t

n filed an emergency petition for enforcement of the CVRA, "seeking an order compelling the Department of Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them various rights conferred upon crime victims under 21 Respondent's Exhibit A Case No. 08-80736-CIV

f Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them

tifiable victims and afford the victims of the rights set forth in the CVRA, prior to the actual entry of the guilty plea. Id. at 393. Ultimately, the Fifth Circuit found the district court erred in entering its ex parte order because the fewer than 200 victims "could be easily reached." Id. at 394-95. Additiona

n filed an emergency petition for enforcement of the CVRA, "seeking an order compelling the Department of Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them various rights conferred upon crime victims under 21 EFTA00078855 Case 9:08-cv-80736-KAM Documen

f Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them

tifiable victims and afford the victims of the rights set forth in the CVRA, prior to the actual entry of the guilty plea. Id. at 393. Ultimately, the Fifth Circuit found the district court erred in entering its ex parte order because the fewer than 200 victims "could be easily reached." Id. at 394-95. Additiona

n filed an emergency petition for enforcement of the CVRA, "seeking an order compelling the Department of Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them various rights conferred upon crime victims under 21 EFTA00230086 Case 9:08-cv-80736-KAM Documen

f Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them

ntifiable victims and afford the victims of the rights set forth in the CVRA, prior to the actual entry of the guilty plea. Id at 393. Ultimately, the Fifth Circuit found the district court erred in entering its ex pane order because the fewer than 200 victims "could be easily reached." Id. at 394-95. Additional

n filed an emergency petition for enforcement of the CVRA, "seeking an order compelling the Department of Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them various rights conferred upon crime victims under 21 08-80736-CV-MARRA 000840 EFTA00230664 Cas

f Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them

ntifiable victims and afford the victims of the rights set forth in the CVRA, prior to the actual entry of the guilty plea. Id at 393. Ultimately, the Fifth Circuit found the district court erred in entering its ex pane order because the fewer than 200 victims "could be easily reached." Id. at 394-95. Additional

asonably heard at plea proceedings.382 On November 2, 2011, U.S. Senator Jon Kyl, a co-sponsor of the CVRA, sent a letter to Attorney General Eric Holder, arguing that the 2011 Guidelines revisions “conflict[ed] quite clearly with the CVRA’s plain language” because the 2011 Guidelines did “not extend

the CVRA, sent a letter to Attorney General Eric Holder, arguing that the 2011 Guidelines revisions “conf

was intended to be broad,” as well as being a “mechanism[]” to ensure that victims were treated with fairness. In denying the victims relief, the Fifth Circuit nevertheless concluded that the district court “failed to accord the victims the rights conferred by the CVRA.”346 In particular, the Fifth Circuit

list of Arca Disciplinary Actions (Position: ETP Holder Limited Partner) For internal use only SDNY_GM

or Appellee. JUDGES: Tjoflat and Hatchett, Circuit Judges, and Garza, • Senior Circuit Judge. • Honorable Reynaldo G. Garza. U.S. Circuit Judge for the Fifth Circuit. sitting by designation. OPINION BY: TJOFLAT OPINION ["6O3] TJOFLAT, Circuit Judge: This private antitrust dispute concerns the alleged attempt o

victims.” The victims sought appellate review in the Fifth Circuit.°’ There, the court concurred with the district c

Shortly after the Department released its opinion, one of the CVRA’s congressional sponsors, then-Senator Jon Kyl, sent a letter to Attorney General Enc Holder strenuously objecting to the Department’s conclusions. Senator Kyl directly stated his view that “[w]hen Congress enacted the ' Scott Campbell, Step

to a criminal defendant in similar circumstances. If prosecutors have sufficient information to provide notice 3 Letter from Jon Kyl, U.S. Sen., to Eric H. Holder, Jr., Att’y Gen. (June 6, 2011), reprinted in 157 Conc. REc. $3608 (daily ed. June 8, 2011) (statement of Sen. Jon Kyl). 4 18 USC. § 3771(c\(1). 5

Shortly after the Department released its opinion, one of the CVRA's congressional sponsors, then-Senator Jon Kyl, sent a letter to Attorney General Eric Holder strenuously objecting to the Department's conclusions. Senator Kyl directly stated his view that "when Congress enacted the [*62] CVRA, it intended t

before charges have been filed, courts have uniformly agreed with the victims’ position. Perhaps the leading case to date to assess this question is the Fifth Circuit's decision in In re Dean. °° There, a wealthy corporate criminal defendant reached a generous plea deal with the Government - a deal that the Governmen

? It was against that backdrop that Senator Kyl gave the example of conferring about proceedings "after charging." In his letter to Attorney General Holder, Senator Kyl also noted that he had: made clear that crime victims had rights under the CVRA even before an indictment is filed. For example, ... I

t proceedings "after charging." In his letter to Attorney General Holder, Senator Kyl also noted that he had: made clear

eached. In rejecting the Department’s posi- tion, the Fifth Circuit held that “the govern- ment should have fashioned

SENATE, Washington, DC, June 6, 2011. Hon. ERIC H. HOLDER, Jr., Attorney General; U.S. Department of Justice, Washington, DC. DEAR ATTORNEY GENERAL HOLDER: I am writing about the Justice Department’s im- plementation of the Crime Victims’ Rights Act--an act that I co-sponsored in 2004. These questions r

U.S. Department of Justice, Washington, DC. DEAR ATTORNEY GENERAL HOLDER: I am writing about the Justice Department’s im-