DOJ-OGR-00000398.jpg

CasSecdesbe-cr-00490-RMB Document 18 Filed 07/16/1 Judge Marrah, 9 Page 12 of 18 12 Justice at the time did not believe The predicate is a The petitioners have ina th the petitioners as to the The issue of remedy your Honor. [ may very briefly? the defense argument here are arguing that sent up a flag lsewher That's Florida has argued in papers Florida believed, from anywhere else, investigation was not shoveled to including the nonprosecution ticular because the 1 prior to the government's entering the agreement. 2 The Department of 3 the CVRA extended absent a federal charge. 4 federal crime that harms a victim. 5 vigorously asserted a different position. 6 summary judgment motion, agreed wit 7 Fault of the government in not conferring. 8 is before Judge Marrah at the present time, 9 THE COURT: Okay. 10 MR. ROSSMILLER: Your Honor, if 11 THE COURT: Yes. 12 MR. ROSSMILLER: The crux of 13 [ think cuts precisely the other way. They 14 the Southern District of Florida has sort of 15 that these prosecutions could be undertaken 16 true. The Southern District of 17 that they believed, the Southern District of 18 that the nonprosecution agreement was limited to that district. 19 They have said that out loud and in public and in their 20 positions in filing. 21 So certainly this 22 the Southern District of New York 23 the Department of Justic W xpect that 24 agreement will not be an impediment, in par 25 defendant certainly did not lack for sophist tLicated counsel in SOUTHE RN DISTR CT RE PORT (212) ERS, 805-0300 2) DOJ-OGR- 00000398