4
Shared Docs
2
Same-Page
6 / 4
Mentions
sufficient—cannot survive either a "plain language" test or the rule of lenity as they have been authoritatively construed in the recent Santos and Cuellar cases. The statute cannot be read otherwise. As the Cuellar decision makes clear, a proper interpretation of a federal criminal statute is guided "
upreme Court decisions addressing that element. See Hansen v. Huff, 291 U.S. 559 (1934); Mortensen v. United States, 322 U.S. 369 (1944). Santos and Cuellar speak loudly and clearly against prosecutors seeing such elasticity in federal criminal statutes, including those enacted to protect important fede
will understand, of what the law intends to do if a certain line is passed!" Arthur Andersen LLP v. United States, 544 U.S. 696, 703 (2005) (quoting McBoyle v. United States, 283 U.S. 25, 27 (1931)) (citation omitted). Two recent Supreme Court decisions dramatically underscore these principles and help
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 do here with
upreme Court decisions addressing that element. See Hansen v. Huff, 291 U.S. 559 (1934); Mortensen v. United States, 322 U.S. 369 (1944). Santos and Cuellar speak loudly and clearly against prosecutors seeing such elasticity in federal criminal statutes, including those enacted to protect important fede
ill understand, of what the law intends to do if a certain line is passed.'" Arthur Andersen LLP v. United States, 544 U.S. 696, 703 (2005) (quoting McBoyle v. United States, 283 U.S. 25, 27 (1931)) (citation omitted). Two recent Supreme Court decisions dramatically underscore these principles and help
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 demonstrate the subst
Page: HOUSE_OVERSIGHT_012137 →will understand, of what the law intends to do if a certain line is passed.”” Arthur Andersen LLP v. United States, 544 U.S. 696, 703 (2005) (quoting McBoyle v. United States, 283 USS. 25, 27 (1931)) (citation omitted), Two recent Supreme Court decisions dramatically underscore these principles and help t
Page: HOUSE_OVERSIGHT_012145 →e 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 impermissibly elas
Page: EFTA00013812 →will understand, of what the law intends to do if a certain line is passed!" Arthur Andersen LLP v. United States, 544 U.S. 696, 703 (2005) (quoting McBoyle v. United States, 283 U.S. 25, 27 (1931)) (citation omitted). Two recent Supreme Court decisions dramatically underscore these principles and help
Page: EFTA00013814 →Entities connected to both Cuellar and McBoyle

Jeffrey Epstein
PERSON
Santos
PERSON
United States
LOCATIONJane Doe
PERSON
Bailey
PERSON
Julie K. Brown
PERSONthe Eleventh Circuit
ORGANIZATION
George W. Bush
PERSONEvans
PERSON
Supreme Court
ORGANIZATION
Virginia Giuffre
PERSONMurrell
PERSON
the Executive Branch
ORGANIZATION
Alexander Acosta
PERSON
Department of Justice
ORGANIZATIONBoehm
PERSON
the United States Supreme Court
ORGANIZATION
Kutun
PERSONNorth Miami
LOCATIONDepartmental
ORGANIZATION