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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
r talked to Mr. Epstein prior to her arrival at his house; and 3) she lied about her age not only to Mr. Epstein, but, in fact, to the world on her MySpace page when she said that she was 18 years old. It is, then, also worth noting in this regard that 18 U.S.C. §§2243(c) provides an affirmative defense
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
r talked to Mr. Epstein prior to her arrival at his house; and 3) she lied about her age not only to Mr. Epstein, but, in fact, to the world on her MySpace page when she said that she was 18 years old. It is, then, also worth noting in this regard that 18 U.S.C. §§2243(c) provides an affirmative defense
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
Page: EFTA00013788 →r talked to Mr. Epstein prior to her arrival at his house; and 3) she lied about her age not only to Mr. Epstein, but, in fact, to the world on her MySpace page when she said that she was 18 years old. It is, then, also worth noting in this regard that 18 U.S.C. §§2243(c) provides an affirmative defense
Page: EFTA00013796 →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
Page: EFTA00013797 →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 →or talked to Mr. Epstein prior to her arrival at his house; and 3) she lied about her age not only to Mr. Epstein, but, in fact, to the world on her MySpace page when she said that she was 18 years old. Itis, then, also worth noting in this regard that 18 U.S.C. §§2243(c) provides an affirmative defense i
Page: HOUSE_OVERSIGHT_012195 →Entities connected to both Cuellar and MySpace

Jeffrey Epstein
PERSON
Marc Rich
PERSON
Palm Beach
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Bill Clinton
PERSONJane Doe
PERSON
Barry Diller
PERSONJoe Recarey
PERSONGerald Lefcourt
PERSON
Alexander Acosta
PERSONRoy Black
PERSON
Ken Starr
PERSON
Virginia Giuffre
PERSON
Michael Reiter
PERSONthe Southern District
LOCATION
Jay Lefkowitz
PERSON
Julie K. Brown
PERSON