Epstein Secrets

SMITH,CONSTANCE GRABOW,JOHN C INGBER,LAWRENCE DUNST,LAURENCE D SCHUSTER,

R,FRANKLYN P LAVERTY,ANNE M GRIFFIS,NIXON MARCUS,JEFFREY A SUMMERS,RUTH A

e proposal and accompanying note, I am concerned that the limits on subpoenas found in the United States Supreme Court's decision in United States v. Nixon 734 might be vitiated by a broad rule. To ensure courts consistently apply Nixon's substantive and procedural standards to victim-related subpoenas,

3 Cassell, Proposed Amendments, supra note 4, at 884. 384 Proposed Amendments, supra note 71. 385 CVRA Subcommittee Memo, supra note 66, at 18. 386 Singer v. United States, 380 U.S. 24, 35 (1965) ("Trial by jury has been established by the Constitution as the "normal and ... preferrable mode of disposin

quash subpoena directed to kidnapping victim's father for lack of materiality). 93 See Fed. R. Crim. P. 17(c)(Q). °4 See generally United States v. Nixon, 418 U.S. 683, 689 (1974). 95 See id. at 699. DAVID SCHOEN HOUSE_OVERSIGHT_017739 --- PAGE BREAK --- Page 26 of 52 2005 B.Y.U.L. Rev. 835, *879

ations omitted). The hardship to the victim was established via affidavits from the victim's family provided to the court by the prosecutor. 214 See Singer v. United States, 380 U.S. 24, 35 (1965) ("Trial by jury has been established by the Constitution as the "normal and preferable mode of disposing of