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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
, 689 (1972)). 1© See, e.g., United States v. Alvarado, 440 F.3d 191, 196 (4th Cir. 2006). 7 OLC CVRA Rights Memo, supra note 2, at 14 n.15 (citing Hanrahan v. United States, 348 F.2d 363, 366 n.6 (D.C. Cir. 1965)),; see WAYNE R. LAFAVE ET AL., CRIMINAL PROCEDURE § 6.4(e), at 670 (3d ed. 2007) (“There is
Page: HOUSE_OVERSIGHT_014069 →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 →, 689 (1972)). 76 See, e.g., United States v. Alvarado, 440 F.3d 191, 196 (4th Cir. 2006). ” OLC CVRA Rights Memo, supra note 2, at 14 n.15 (citing Hanrahan v. United States, 348 F.2d 363, 366 n.6 (D.C. Cir. 1965)); see Wayne R. LaFave et al., Criminal Procedure § 6.4(e), at 670 (3d ed. 2007) ("There is a
Page: HOUSE_OVERSIGHT_017624 →ARTICLE: Treating Crime Victims Fairly: Integrating Victims into the Federal Rules of Criminal Procedure
participants in the criminal justice process. As the Fifth Circuit explained in reversing a trial court which had al
ra Lyn Bassett, Recusal and the Supreme Court, 56 Hastings L.J_ 657, 678-79 (2005) (citing United States v. Will, 449 U.S. 200, 211-12 & n.12 (1980); Hanrahan v. Hampton, 446 U.S. 1301, 1301 (1980)). 255 Model R. Prof] Conduct 4.4(a) (2007); see also ABA Criminal Justice Study, Standard 4-4.3 (1993). 256
Page: HOUSE_OVERSIGHT_017668 →Entities connected to both the Fifth Circuit and Hanrahan

Jeffrey Epstein
PERSON
United States
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSONLeon Black
PERSON
Paul Cassell
PERSON
George W. Bush
PERSONSecond Circuit
ORGANIZATION
Supreme Court
ORGANIZATIONMaria Farmer
PERSON
Harvey Weinstein
PERSON
Prince Andrew
PERSON
Julie K. Brown
PERSON
Alexander Acosta
PERSON
S.J. Quinney College of Law
ORGANIZATION
A. Marie Villafana
PERSON
Ghislaine Maxwell
PERSONRubin
PERSON
Eric Holder
PERSON