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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
esses. We understand that was apparently not its perceived role. But, CEOS should recognize that at least oneprosecutor in this case — the Chief of the SAO Sex Crimes Division has done so. not only met with and interviewed these witnesses during the course of the 15-month state investigation prior to any federal involvem
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
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
sses. We understand that was apparently not its perceived role. But, CEOS should recognize that at least one prosecutor in this case — the Chief of the SAO Sex Crimes Division has done so. Lana Belohlavek not only met with and interviewed these witnesses during the course of the 15-month state investigation prior to any fe
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
Page: EFTA00013788 →sses. We understand that was apparently not its perceived role. But, CEOS should recognize that at least one prosecutor in this case — the Chief of the SAO Sex Crimes Division has done so. Lana Belohlavek not only met with and interviewed these witnesses during the course of the 15-month state investigation prior to any fe
Page: EFTA00013791 →Entities connected to both Santos and the SAO Sex Crimes Division

Jeffrey Epstein
PERSON
United States
LOCATION
George W. Bush
PERSON
Virginia Giuffre
PERSONJane Doe
PERSON
the United States Supreme Court
ORGANIZATION
Alexander Acosta
PERSON
Woody Allen
PERSON
Cuellar
PERSONthe Southern District
LOCATION
Atlanta
LOCATION
Mike Pence
PERSON
Jay Lefkowitz
PERSONMurrell
PERSONEvans
PERSON
Bailey
PERSON
Johns
PERSON
Palm Beach
LOCATIONBerger
PERSONOwens
PERSON