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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
here. In fact, the United States Supreme Court prohibited the criminalization of travel under identical circumstances over a half century ago. Sce, Mortenson v. United Stalo, 322 U.S. 369,374 (1944) (intention to engage in proscribed conduct must "exist before the conclusion of the interstate journey and
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
here. In fact, the United States Supreme Court prohibited the criminalization of travel under identical circumstances over a half century ago. Sis, Mortenson v. United States 322 U.S. 369, 374 (1944) (intention to engage in proscribed conduct must "exist before the conclusion of the interstate journey an
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 →here. In fact, the United States Supreme Court prohibited the criminalization of travel under identical circumstances over a half century ago. Sis, Mortenson v. United States 322 U.S. 369, 374 (1944) (intention to engage in proscribed conduct must "exist before the conclusion of the interstate journey an
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 →Entities connected to both Cuellar and Mortenson

Jeffrey Epstein
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Santos
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Bailey
PERSONMurrell
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Johns
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George W. Bush
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Alexander Acosta
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Jay Lefkowitz
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Virginia Giuffre
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Atlanta
LOCATIONJane Doe
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Madison
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United States
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the United States Supreme Court
ORGANIZATIONDwight York
PERSONBerger
PERSONPuche
PERSONOwens
PERSONMySpace
ORGANIZATION