Epstein Secrets

, 373 U.S. 83, 86 (1963) (holding prosecution's withholding of the confession of defendant's confederate violated defendant's due process rights). 7 Gideon v. Wainwright, 372 U.S. 335, 342 (1963) (extending Sixth Amendment right to assistance of counsel to indigent state criminal defendants); Powell v. A

: Room for Debate (Apr. 9, 2015), hittps://www.nytimes.com/roomfordebate/2015/04/09/are -police-too-quick-to-use-force. 32 See Michael Planty et al, U.S. Dep't of Justice, Female Victims of Sexual Violence, 1994-2010, at 6 (2013), hittps://www.bjs.gov/content/pub/pd{/{vsv9410.pdf (estimating portion of sexual assaults

ion only on a matter that is not in dispute"). 159 Cassell, Proposed Amendments, supra note 4, at 868. 160 Proposed Amendments, supra note 71. 161 U.S. Dep't of Justice, Office for Victims of Crime, Attorney General Guidelines for Victim and Witness Assistance 30 (2005) (defining what can be considered in determining

broadly permits the court in both civil and criminal cases to "request an attorney to represent any person unable to afford counsel." 49° And before Gideon v. Wainwright, *°° courts could request 45 Td. 46 Td. 47 Tn possible response to such concerns as I raise here, the Advisory Committee modified the

nesses),; Pub L. No. 101-647, 104 Stat. 4789 (1990). 35 Victim and Witness Protection Act, Pub. L. No. 97-291, 6(a), 96 Stat. 1248, 1252 (1982). 36 U.S. Dep't of Justice, Office of the Att'y Gen., Attorney General Guidelines for Victim and Witness Assistance (1995). 37 Td. 38 U.S. Dep't of Justice, Office of the Att'

th civil and criminal cases. 3!! While these cases do not directly involve [*913] appointment of counsel for crime victims, their principles 309 Cf. Gideon v. Wainwright, 372 U.S. 335, 344 (1963) (discussing "fairness" to the defendant as a reason for recognizing a right to appointed counsel). 310 150 C