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78), the search warrant affidavit in this case reveals knowing and reckless falsehoods and omitted material information. This is precisely the type the United States Supreme Court sought to guard against. The age of the alleged victims, and of Mr. Epstein's intent in that regard, is an clement of the crimes that must be prove
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
78), the search warrant affidavit in this case reveals knowing and reckless falsehoods and omitted material information. This is precisely the type the United States Supreme Court sought to guard against. The age of the alleged victims, and of Mr. Epstein's intent in that regard, is an element of the crimes that must be prove
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
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 →78), the search warrant affidavit in this case reveals knowing and reckless falsehoods and omitted material information. This is precisely the type the United States Supreme Court sought to guard against. The age of the alleged victims, and of Mr. Epstein's intent in that regard, is an element of the crimes that must be prove
Page: EFTA00013795 →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 →1978), the search warrant affidavit in this case reveals knowing and reckless falsehoods and omitted material information. This is precisely the type the United States Supreme Court sought to guard against. The age of the alleged victims, and of Mr. Epstein’s intent in that regard, is an element of the crimes that must be proven
Page: HOUSE_OVERSIGHT_012193 →Entities connected to both the United States Supreme Court and Cuellar

Jeffrey Epstein
PERSONJane Doe
PERSON
United States
LOCATION
George W. Bush
PERSONthe Southern District
LOCATION
Julie K. Brown
PERSON
Supreme Court
ORGANIZATION
Jay Lefkowitz
PERSON
Virginia Giuffre
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATION
Santos
PERSONFlorida Bar
ORGANIZATIONthe Eleventh Circuit
ORGANIZATION
Alexander Acosta
PERSON
Bill Clinton
PERSON
Marc Rich
PERSONthe Florida Supreme Court
ORGANIZATIONRoy Black
PERSON
Bailey
PERSON