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atement reveals how inapposite a federal prosecution is to the facts in this case. Importantly, we note that the CEOS review was conducted prior to the Supreme Court's very recent decisions in Santos and Cuellar, which we believe—illuminating as they do the Court's interpretive methodology when it comes to federal
erson ..."). § 2423(b) is not such a statute. Federal court decisions watering down the "for the purpose of " requi ment fly in the face of the two Suprems Court decisions addressing that element. See Hansen'. Huff, 291 U.S. 559 (1934); Mortensen. United States, 322 U.S. 369 (1944). Santos and Cuellar speak l
the Deputy Attorney General end federal involvement in this matter so that the State of Florida may resolve this case appropriately. Summary of the Facts Mr. Epstein has maintained a home in Palm Beach, Florida for the past 20 years. While there, he routinely conducted business, received medical atte
t has made it abundantly plain that, whatever the outcome of this litigation, the agreement it made with Mr. Epstein will stand. indeed, controlling Supreme Court case law prevents it from doing otherwise. Mr. Epstein has fully performed his side of the bargain with the government, and when a bargain is based
1 a Plaintiff's MOTION Jane Doe #1 and Jane Doe #2's Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts by Jane Doe. (Edwards, Bradley) (Entered: 03/21/2011) • 03/21/2011 52 Plaintiffs MOTION Jane Doe #1 and Jane Doe #2's Motion for Order Directing
n roa Plaintiffs MOTION Jane Doe #1 and Jane Doe #2's Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts filed by United States of America. (Lee, Dexter) (Entered: 04/07/2011) 04/07/2011 52 RESPONSE in Opposition rejQ Plaintiffs MOTION Jane Doe #1 and
ions—a description used by CEOS itself—it cannot be shown that Mr. Epstein violated any of the three federal statutes identified by prosecutors. As the Supreme Court's recent decisions in Santos and Cuellar make clear, federal law may not be stretched in that manner, and the current federal investigation relies, as
the Deputy Attorney General end federal involvement in this matter so that the State of Florida may resolve this case appropriately. Summary of the Facts Mr. Epstein has maintained a home in Palm Beach, Florida for the past 20 years. While there, he routinely conducted business, received medical atte
atement reveals how inapposite a federal prosecution is to the facts in this case. Importantly, we note that the CEOS review was conducted prior to the Supreme Court's very recent decisions in Santos and Cuellar, which we believe—illuminating as they do the Court's interpretive methodology when it comes to federal
the Deputy Attorney General end federal involvement in this matter so that the State of Florida may resolve this case appropriately. Summary of the Facts Mr. Epstein has maintained a home in Palm Beach, Florida for the past 20 years. While there, he routinely conducted business, received medical atte
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