Epstein Secrets

SAWN., ta KAREN LLCM 'C.CALVINWARRINER IS MOM= MIN. L. MOM JR, SHARDIOLOVIS bOAM CFRTIFC0 61.5116111101ED wantiCv um ARnJlO ▪ Aussocnusuris WISSISSPPI ' NEW HAMM* WA CC PARHAM'S: VIVIAN AY/ASMARA MNUf /A. DUFRESNE OAVO W MAMIE JOIN O HOPICHS CIANA LAN/CC MOOR/A It KNAPP MGM L tEOPORO JR.

ber old i,2010 a copy of the foregoing has been served via U.S. Mail and email transmittal to all those on the attached service list. Jack Scarola Searcy, Denney, Scarola, Bamhart & Shipley By: 37 OL No.: 169440 EFTA00188902 Case 9:08-cv-80736-KAM ,current 291-15 Entered on FLSD L_ Ket 01/21/20

rts concluded 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 characte

ing such an approach would be difficult.*” Presumably the Justice Department has already been providing such rights in at least Texas, Louisiana, and Mississippi to comply with the Fifth 197 See 18 U.S.C. §§ 2422(b), 2423(b), (e) (2012). 198 A more substantial summary of the case is available in case filings

that a victim 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(

ng such an approach would be difficult. 7° Presumably the Justice Department has already been providing such rights in at least Texas, Louisiana, and Mississippi to comply with the Fifth [*95] Circuit's 2008 ruling in In Re Dean, which held that the CVRA extends rights to victims before defendants are charged