Epstein Secrets

63 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003278 EFTA00157660 LAW OFFICES ALLEN GUTHRIN: MCHUGH & THOMAS, PLLC GEORGE 43.GUIRRE ROSERT e. PALEN RFJXCCA A. SETTS R. IERRAKE ROCOERS CANSO IS THOMAS ONES S. ARNO° DAVOS HARDY Mt SCOTT WCKLINE PANELS I. CANINO PA

at organized rings of individuals who engage in the business of human trafficking, involving both a commercial and coercive component. As President Bush has noted: generally speaking, trafficking in persons refers to actions, often including the use of force, fraud or coercion, to compel someone int

ing both a commercial and coercive component. As President Bush has noted: generally speaking, trafficking in pe

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

at organized rings of individuals who engage in the business of human trafficking, involving both a commercial and coercive component. As President Bush has noted: generally speaking, trafficking in persons refers to actions, often including the use of force, fraud or coercion, to compel someone int

ing both a commercial and coercive component. As President Bush has noted: generally speaking, trafficking in pe

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

at organized rings of individuals who engage in the business of human trafficking, involving both a commercial and coercive component. As President Bush has noted: generally speaking, trafficking in persons refers to actions, often including the use of force, fraud or coercion, to compel someone int

ing both a commercial and coercive component. As President Bush has noted: generally speaking, trafficking in pe

Department of Justice 950 Pennsylvania Avenue, N.W. Washington, D.C. 20530 Dear Mr. Roth: TELEPHON

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

& ELLIS LLP AND ATTILJAIRU PARTNERSHIPS Kenneth W. Starr To Cell Writer Madly (213) 680-8440 ksta

A00209852 KIRKLAND & ELLIS LLP Congress to speak more clearly and keeps courts from making criminal law in Congress's stead." Slip op. at 6.I In Cuellar, the Court examined the link between the money-laundering statute's mens rea requirement and the underlying elements of the offense. After a careful

o Suprems Court decisions addressing that element. See Hansen'. Huff, 291 U.S. 559 (1934); Mortensen. 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

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

ving both a commercial and coercive component. As President Bush has noted: generally speaking, trafficking in pe

mbat organized rings of individuals who engage in the business of human trafficking, involving both a commercial and coercive component. As President Bush has noted: generally speaking, trafficking in persons refers to actions, often including the use of force, fraud or coercion, to compel someone into