Paul G. Cassell, Esq. 332 S. 1400 E., Room 101 Salt Lake City, UT 84112 (801) 585-5202 (phone) (801) 581-6897 (facsimile) E-mail: cassellpOlaw.utah.edu January 25, 2010 Re: United States g Alfredo Rodriquez, No. 9:09-MJ-08308-LRJ-1 I am writing to assert the rights of my clients as victims in the above-captioned case. It have tried to reach you several times by telephone, but have thus far been unsuccessful. You may already be treating my clients as victims. But in the interests of avoiding any confusion and to make sure that they don't miss notice of any future events in this criminal case, I am writing to formally notify you that my three clients (whose names are known to the government and who are identified in court pleadings as LM., E.W. and Jane Doe) are all asserting their rights under the Crime Victims Rights Act, 18 U.S.C. § 3771. As you know from another case we have worked on together, the CVRA protects all those who have been "directly and proximately harmed" as the result of the commission of a federal offense. 18 U.S.C. § 3771(e). My three clients were all pursuing civil discovery in the civil cases that Mr. Rodriguez obstructed by corruptly concealing a document with extremely important information in it that would help them prove their case (the so-called "black book"). My clients would like to exercise all of their rights under the Crime Victims' Rights Act, 18 U.S.C. § 3771, including the right to be notified of court events, to confer with the prosecutor as necessary, to be treated with fairness, and (if there is a conviction in this matter) to be heard at sentencing. As you know, the relevant case law gives crime victims the right to confer with prosecutors regarding any plea bargain that might be reached in cases such as this, even before an indictment has been filed. See, e.g., In re Dean, 527 F.3d 391 (5th Cir. 2008) (finding the Government violated the CVRA in not conferring with victims in case before filing a compl