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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
e described unless there is an appropriate, articulable reason not to do so.” Id., Art. II, ¶ C. 399 Id., Art. IV, ¶ B.1. 400 Searcy v. Paletz, 2007 WL 1875802, at *5 (D.S.C. June 27, 2007) (an inmate is not considered a crime victim for purposes of the CVRA until the government has filed c
Crime Victims' Rights During Criminal Investigations? Applying the Crime Victims' Rights Act Before Criminal Charges Are Filed
victims.” The victims sought appellate review in the Fifth Circuit.°’ There, the court concurred with the district c
ded 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 characterizes Turn
Page: HOUSE_OVERSIGHT_014057 →CRIMINAL LAW: CRIME VICTIMS' RIGHTS DURING CRIMINAL INVESTIGATIONS? APPLYING THE CRIME VICTIMS' RIGHTS ACT BEFORE CRIMINAL CHARGES ARE FILED
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
Page: HOUSE_OVERSIGHT_017613 →ctim 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(c)(3)(A).
Page: HOUSE_OVERSIGHT_017616 →Entities connected to both the Fifth Circuit and Paletz

Jeffrey Epstein
PERSON
United States
LOCATIONJane Doe
PERSON
Bradley Edwards
PERSON
Department of Justice
ORGANIZATION
Paul Cassell
PERSONLeon Black
PERSONSecond Circuit
ORGANIZATION
Alexander Acosta
PERSONMaria Farmer
PERSON
A. Marie Villafana
PERSON
Prince Andrew
PERSON
S.J. Quinney College of Law
ORGANIZATIONRubin
PERSON
the University of Utah
ORGANIZATION
Eric Holder
PERSON
Salt Lake City
LOCATION
Michigan
LOCATIONScott Rothstein
PERSON
Bill Clinton
PERSON