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This document is page 76 of a legal article (Vol. 104) by Cassell et al., produced to the House Oversight Committee. It argues against the Office of Legal Counsel's (OLC) interpretation of the Crime Victims' Rights Act (CVRA). The text contends that the OLC incorrectly asserts that victim rights only attach after formal charges are filed, arguing instead that the Department of Justice is required by statute (VRRA) and policy to identify victims earlier, such as during the 'target letter' phase of an investigation.