Epstein Secrets

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

criminal prosecution" does not commence with the filing of a complaint and issuance of an arrest warrant, but only upon the return of an indictment. Kirby. Illinois, 406 U.S. 682, 688-690 (1972). See also United States Pace, 833 KM 1307, 1312 (9th Cir. 1987) (filing of complaint and issuance of arres

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

internal quotation marks omitted). 4 See, e.g., Texas v. Cobb, 532 U.S. 162, 172-73 (2001). 1 Brewer v. Williams, 430 U.S. 387, 398 (1977) (quoting Kirby v. Illinois, 406 U.S. 2, 689 (1972)). 1© See, e.g., United States v. Alvarado, 440 F.3d 191, 196 (4th Cir. 2006). 7 OLC CVRA Rights Memo, supra not

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

nternal quotation marks omitted). ™ See, e.g., Texas v. Cobb, 532 U.S. 162, 172-73 (2001). 75 Brewer v. Williams, 430 U.S. 387, 398 (1977) (quoting Kirby v. Illinois, 406 U.S. 682, 689 (1972)). 76 See, e.g., United States v. Alvarado, 440 F.3d 191, 196 (4th Cir. 2006). ” OLC CVRA Rights Memo, supra n