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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
ceeds its bounds. See Tab 12, November 2, 1994 Memorandum from Assistant Attorney General to the Hon. Abner J. Mikva, Counsel To The President, on Presidential Authority To Decline To Execute Unconstitutional Statutes, available at http://www.usdoj.gov/olcinonexcut.hrtn. In this case, the text, structure, and histor
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
. See Tab 12, November 2, 1994 Memorandum from Assistant Attorney General Walter Dellinger to the Hon. Abner J. Mikva, Counsel To The President, on Presidential Authority To Decline To Execute Unconstitutional Statutes, available at http://www.usdoj.gov/oldnonexcut.htm. In this case, the text, structure, and history
t 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 its foundation, on imperm
. See Tab 12, November 2, 1994 Memorandum from Assistant Attorney General Walter Dellinger to the Hon. Abner J. Mikva, Counsel To The President, on Presidential Authority To Decline To Execute Unconstitutional Statutes, available at http://www.usdoj.gov/olc/nonexcut.htm. In this case, the text, structure, and history
Entities connected to both Santos and Presidential Authority

Jeffrey Epstein
PERSON
United States
LOCATION
George W. Bush
PERSON
Julie K. Brown
PERSON
Marc Rich
PERSON
Lesley Groff
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATION
Bill Clinton
PERSON
Supreme Court
ORGANIZATIONJane Doe
PERSON
Alexander Acosta
PERSONMcBoyle
PERSON
Cuellar
PERSONSanchez
PERSONthe Eleventh Circuit
ORGANIZATIONthe Southern District
LOCATION
Samuel Alito
PERSONRoy Black
PERSON
Barry Diller
PERSON