fore charges were filed but were subject to the outer limit that the Government has at least “contemplated” charges.” Similarly, in United States v. Oakum,” the District Court for the Easter District of Virginia considered a claim that CVRA nghts did not apply until after a defendant had been convicted.

re charges were filed but were subject to the outer limit that the Government has at least "contemplated" charges. 7! Similarly, in United States v. Oakum, ” the District Court for the Eastern District of Virginia considered a claim that CVRA rights did not apply until after a defendant had been convict

re Acker, 596 F.3d 370, 373 (6th Cir. 2010). The district courts that have considered the question are divided. Compare, e.g., 1' United States it Oakum, No. 3:08CR132, 2009 WL 790042, at *2 (E.D. Va. Mar. 24, 2009) (holding that CVRA rights can attach prior to the commencement of criminal proceedi

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