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file this response in
opposition the Government's Cross-Motion for Summary Judgment (DE 401-2). In support,
they state:
I. INTRODUCTION
As the victims explained in their motion ... contend
that it is entitled to summary judgment on this case. DE 401-2. In a concurrently-filed
pleading, the victims have responded to the Government's proposed "undisputed" facts ... want to be treated as a victim with rights
provided by the CVRA." DE 401-2 at 3. The Government points to certain statements made by
Jane Doe 2, while
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well as responses
to the facts (DE 407) and to the motion (DE 401-2) from the Government. Boiled down to its
essence, however, this case remains a simple ... victims, it had satisfied
the CVRA's "reasonable right to confer." DE 401-2 at 9. But as the facts recounted above made
clear, the Government assiduously concealed from ... State guilty pleas.
While the Government tries gamely to defend its actions, DE 401-2 at 15-20, the
undisputed facts show that in January (and later) 2008, well after
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simultaneously contesting the victims' motion while raising its own motion for summary
judgment. DE 401-2. This pleading made numerous representations about the internal
deliberations of the Government during ... critical time frame. See, e.g., DE 401-2 at 10-3; DE
403-19 at 2-23. For example, consider the following arguments made in the Government's
memorandum
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