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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
of Justice Child Exploitation and Obscenity Section ("CEOS") regarding the federal investigation of Jeffrey Epstein by the United States Attorney's Office for the Southern District of Florida ("USAO"),I I will refrain from recounting Mr. Epstein's arguments in detail here, but, rather, will highlight salient points responsive
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
of Justice Child Exploitation and Obscenity Section ("CEOS") regarding the federal investigation of Jeffrey Epstein by the United States Attorney's Office for the Southern District of Florida ("USAO").' I will refrain from recounting Mr. Epstein's arguments in detail here, but, rather, will highlight salient points responsive
s after his release, he moved into his daughter Talia's dorm at Sarah Lawrence, where he met her friends, including Isabella and Felicia's brother, Santos. Santos, Felicia, their sister Yalitza, Isabella, and several Sarah Lawrence students would end up living with Ray on and off for the next several y
ernment is represented by Michael D. Lockard, Sidhardha ICamaraju, David W. Denton Jr., Jonathan Rebold and Kiersten Fletcher of the U.S. Attorney's Office for the Southern District of New York. Halkbank is represented by Andrew Hruska, William Johnson and Jacob Gerber of King & Spalding LLP. The case is U.S. v. Zarrab et al., case number
Entities connected to both Santos and Southern District of New York

Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
Alexander Acosta
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSONJane Doe
PERSONJack Goldberger
PERSON
George W. Bush
PERSONLeon Black
PERSON
Scarlett Johansson
PERSON
Julie K. Brown
PERSON
Alan Dershowitz
PERSONWeiss
PERSON
United States Department of Justice
ORGANIZATIONRobert C. Josefsberg
PERSON