Epstein Secrets

—and we needn't do so even in this case. We cite Professor Cassell's article here (and elsewhere) for several reason

agreement that these "proceeding"-focused rights apply only after the filing of a complaint or criminal charges. See Reply in Supp. of Pet. at 17; Paul G. Cassell, et aL, Crime Picini's' Rights During Criminal Investigations? Applying the Crime Victims' Rights Act Before Criminal Charges Are Filed, 104 J. of

they assert that the term "case" can "refer both to a judicial case before a court and an investigative case pursued by a law enforcement officer," Cassell et al., supra, at 72 (emphasis added).9 Although it's true, at least in the abstract, that the term "case" can mean either thing, in legal parlanc

civil or criminal proceeding, action, suit, or controversy at law or in equity <the parties settled the case>" and "[a] criminal investigation <the Manson case>." Case, Black's Law Dictionary 258-59 (10th ed. 2014). As shown in my factual background, everyone involved in Epstein's case— from AUSA Vill

nsel for Plaintiff in Related Case No. 08-80893 Paul G. Cassell, Esq. Pro Hae Vice 332 South 1400 E, Room 101

Plaintiff in Related Case No. 08-80893 Paul G. Cassell, Esq. Pro Hae Vice 332 South 1400 E, Room 101

nd September 9, 2009 Omnibus Order (DE 293); and Manson v. United States, 244 U.S. 362, 365 (1917). More

e #2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 [email protected] Counsel for Plaintiff in Related Case No. 08-80893 Paul G. Cassell, Esq. Pro Hae Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plai

Plaintiff in Related Case No. 08-80893 Paul G. Cassell, Esq. Pro Hae Vice 332 South 1400 E, Room 101

'the tlueat of prosecution is real, substantial and present."' See August 4, 2009 Order (DE 242) and September 9, 2009 Omnibus Order (DE 293); and Manson v. United States, 244 U.S. 362, 365 (1917). Moreover, as this court knows, the NPA only defers prosecution in the 6 Case 9:08-cv-80119-KAM Doc

nsel for Plaintiff in Related Case No. 08- 80893 Paul G. Cassell, Esq. ProHac Vice 332 South 1400 E, Room 101 S

Plaintiff in Related Case No. 08- 80893 Paul G. Cassell, Esq. ProHac Vice 332 South 1400 E, Room 101 S

and September 9, 2009 Omnibus Order (DE 293); and Manson v. United States, 244 U.S. 362,365 (1917). More

s Counsel for Plaintiff in Related Case No. 08-80893 In related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994 Paul G. Cassell, Esq. Pro Hae Vice 332 South 1400 E, Room IOI 19 Case 9:08-cv-80119-KAM Document 282 Entered on FLSD Docket 08/31/2009 Page 20 of 20 Rich

08-80380, 08-80381, 08-80993, 08-80994 Paul G. Cassell, Esq. Pro Hae Vice 332 South 1400 E, Room IOI

nto play only in those instances where the witness has "reasonable cause to apprehend danger from a direct answer." Hoffman 341 U.S. at 486 (citing Manson v. United States, 244 U.S. 362,365 (1917)). "The claimant must be 'confronted by substantial and 'real,' and not merely trifling or imaginary, haza

y J. Edwards FARMER. JAFFE. WLETSSINrk 17 EFTA00208010 Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05/02/2011 Page 28 of 29 and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane Doe #2 28 EFTA00208011 Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05:022011 Pag

LSD Docket 05/02/2011 Page 28 of 29 and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane

ctionary). But the Government does not disclose that Black's Law Dictionary also clearly defines a "case" as "[a] criminal investigation" as in "the Manson case." BLACK'S LAW DICTIONARY 228 (8th ed. 2004). Accord WEBSTER'S THIRD NEW INTERNATIONAL DICTIONARY 345 (1993) (defining "case" as "a circumstan

red on FLSD Docket 05/02/2011 Page 28 of 29 EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Cit UT 84112 Attorneys for Jane Doe #1 and Jane Doe

. On August 14, 2008, a hearing was held, during which a stipulated set of facts was discussed: THE COURT: So if I can hear from Mr. Edwards or Mr. Cassell first what the Plaintiffs' position [is] as far as where we stand on the record in terms of whether I need additional facts, evidence, or there's g

ctionary). But the Government does not disclose that Black's Law Dictionary also clearly defines a "case" as "[a] criminal investigation" as in "the Manson case." BLACK'S LAW DICTIONARY 228 (8th ed. 2004). Accord WEBSTER'S THIRD NEW INTERNATIONAL DICTIONARY 345 (1993) (defining "case" as "a circumstan

ticle 2 Winter 2014 Crime Victims’ Rights During Criminal Investigations? Applying the Crime Victims’ Rights Act Bebore Criminal Charges Are Filed Paul G. Cassell Nathanael J. Mitchell Bradley J. Edwards Follow this and additional works at: http://scholarlycommons.law.northwestern.edu/jclc o& Part of the Cr

The statute that Congress passed to solve these problems—the Crime Victims’ Rights Act of 2004—-gave victims “the right to participate in the 18 See Cassell, supra note 17, at 848-49. For the pros and cons of the amendment as originally introduced, compare Paul G. Cassell, Barbarians at the Gates? A Reply

g., BLack’s Law Dictionary 243-44 (9th ed. 2009) (defining, among the definitions of “case,” a “test case” as “[a] criminal investigation” as in “the Manson case”); WEBSTER’S THIRD NEW INTERNATIONAL DICTIONARY OF THE ENGLISH LANGUAGE UNABRIDGED 345 (1993) (defining “case” as “a circumstance or situation (

CRIME VICTIMS’ RIGHTS ACT BEFORE CRIMINAL CHARGES 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 Univ

tims in the Federal Rules of Criminal Procedure: Proposed Amendments in Light of the Crime Victims' Rights Act, 2005 BYU L. Rev. 835, 847-50. 18 See Cassell, supra note 17, at 848-49. For the pros and cons of the amendment as originally introduced, compare Paul G. Cassell, Barbarians at the Gates? A Reply

g., Black's Law Dictionary 243-44 (9th ed. 2009) (defining, among the definitions of "case," a "test case" as "[a] criminal investigation" as in "the Manson case"); Webster's Third New International Dictionary of the English Language Unabridged 345 (1993) (defining "case" as "a circumstance or situation (