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This legal document analyzes the ambiguity of the Crime Victims' Rights Act (CVRA) concerning when victims' rights attach, particularly before formal charges are filed. It notes that at the time of the 2007 Non-Prosecution Agreement (NPA) in the Epstein case, court precedent was sparse and divided, a situation that continued as of the writing of this report. Because the law was not clear, the Office of Professional Responsibility (OPR) concluded that the prosecutors' failure to consult with victims before signing the NPA did not constitute professional misconduct.