Epstein Secrets

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 Presidential Directive. EFTA

previously set forth herein, and as more fully explained in other submissions related to this case, the recent Supreme Court decisions in Santo and Cuellar make this attempted stretch of the law improper. EFTA00013796 --- PAGE BREAK --- ALLEN GUTHRIE MCHUGH & THOMAS, PLLC Mr. John Roth June 19, 200

omponents that Congress, and administration policy statements intended in 18 U.S.C. § 1591 prosecutions. Evans, and his co-conspirators (Madison and Yearby) were not "Johns." They operated a for profit prostitution ring marked by control of, and extreme violence toward, the victims, who they knew were

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

omponents that Congress, and administration policy statements intended in 18 U.S.C. § 1591 prosecutions. Evans, and his co-conspirators (Madison and Yearby) were not "Johns." They operated a for profit prostitution ring marked by control of, and extreme violence toward, the victims, who they knew were

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

components that Congress, and administration policy statements intended in 18 U.S.C. § 1591 prosecutions. Evans, and his co-conspirators (Madison and Yearby) were not “Johns.” They operated a for profit prostitution ring marked by control of, and extreme violence toward, the victims, who they knew were un