Memorandum characterizing Turner as excluding victims of uncharged conduct.
This document is page 14 of a legal filing or journal article (104 J. Crim. L. & Criminology) submitted to the House Oversight Committee by David Schoen. It argues against the Office of Legal Counsel's (OLC) restrictive interpretation of the Crime Victims' Rights Act (CVRA), specifically regarding whether victim rights attach before formal charges are filed. The text analyzes and distinguishes prior case law (Turner, Paletz, Skinner), arguing that these cases do not preclude CVRA rights during the investigation phase.
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