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

ed States, 817 F. Supp. 2d 1337, 1342-45 (SD. Fla. 2011) (recognizing that 1/8 U.S.C. § 3771(a) can apply before formal charges are filed); Jordan v. Dep't of Justice, 173 F. Supp. 3d 44, 52 (S.D.N.Y. 2016) (citing In re Dean, 527 F.3d at 395); United States v. BP Prod. N. Am., Inc., No. H-07-434, 2008 WL 501321, a

is reasonable in a particular case) [hereinafter Dep't of Justice, Attorney General Guidelines]; see also U.S. Dep'

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

istration of Justice and the Enforcement of Laws: Dep't of Justice Oversight Hearing Before the S. Judiciary Comm.,

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