Epstein Secrets

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

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

makes clear. See, United States v. Madison, 477 F.3d 1312, 1313-1314 (11th Cir. 2007) (Jane Doe 42 stated that she traveled to Atlanta, Georgia with Madison to work as a prostitute). Thus, courts, including the Eleventh Circuit in Evans, have underscored the point that § 1591 simply is not intended to

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

coercive 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

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

ution ring in Evans was not, in fact, entirely intrastate as the companion case of one of the Evans co-defendants makes clear. See, United States v. Madison, 477 F.3d 1312, 1313-1314 (11th Cir. 2007) (Jane Doe #2 stated that she traveled to Atlanta, Georgia with Madison to work as a prostitute). Thus, c

coercive 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

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

nd coercive 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 k