ct of 2004"—in which it concluded, following an exhaustive analysis, that CVRA rights do not apply before the commencement of criminal proceedings. See The Availability of Crime Victims' Rights Under the Crime Victims' Rights Act of 2004, 35 Op. O.L.C. 1 (Dec. 17, 2010). OLC's 2010 opinion reinforced and formalized an earlier 2005 determination that had likewise concluded, "