Epstein Secrets

criminal statute could support both a narrow or broad application of the federal criminal law, "the tie must go to the defendant." United States v. Santos, 553 U.S. and Cuellar v. United States, 553 U.S (June 2, 2008), Slip Op. at 6. 2 February 25, 2003 Trafficking in Persons National Security Presi

AO to do so, it is not in accord with the principles of justice. Indeed, as noted, just a few weeks ago, the Supreme Court underscored this point in Santos and Cuellar. The Court made clear that prosecutorial discretion does not provide the USAO cart blanche to expand criminal statutes as they seek to

E. McHUGH P. 0. BOX 3301 CHARLESTON, WEST VIRGINIA 25333-3394 500 LEE STREET. EAST. SMITE 800 CHARLESTON. WEST VIRGINIA 25301 June 19, 2008 Mr. John Roth Senior Associate Deputy Attorney General Office of the Deputy Attorney General United States Department of Justice 950 Pennsylvania Avenue, N.W.

ecution 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 criminal law—powerfully demonst

Madly (213) 680-8440 [email protected] 777 South Figueroa Street Los Angeles, California 90017 (213)680'8400 www.kirkland.com June 19,2008 John Roth, Esq. Principal Associate Deputy Attorney General Office of the Deputy Attorney General United States Department of Justice 950 Pennsylvania Aven

th Figueroa Street Los Angeles, California 90017 Kenneth W. Starr : To Call Writer Directly: FP Facsimile: www.kirkland.com Dir. Fax: June 19, 2008 John Roth, Esq. Principal Associate Deputy Attorney General Office of the Deputy Attorney General United States Department of Justice 950 Pennsylvania Avenue

secution 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 criminal law—powerfully demonstra

E. MCHUGH P. 0. 00X 3301 CHARLESTON, WEST VIRGINIA 25333-3394 500 LEE STREET. EAST. SMITE 800 CHARLESTON. WEST VIRGINIA 25301 June 19, 2008 Mr. John Roth Senior Associate Deputy Attorney General Office of the Deputy Attorney General United States Department of Justice 950 Pennsylvania Avenue, N.W.

criminal statute could support both a narrow or broad application of the federal criminal law, "the tie must go to the defendant." United States v. Santos, 553 U.S. and Cuellar v. United States, 553 U.S (June 2, 2008), Slip Op. at 6. 2 February 25, 2003 Trafficking in Persons National Security Presi