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

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).

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