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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 →e 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, courts, including the Eleventh Circuit in Evans, have underscored the point that § 1591 simp
Page: EFTA00013797 →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 →e Evans co-defendants 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 simp
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
tlanta Spa Killings. NBC Nightly News (3/22, story 6, 1:30, Holt, 5.95M) reported, "We're back now with protests and demands for answers after the Atlanta spa killings as federal officials said they don't have evidence yet of a hate crime and some communities take new steps to keep Asian-Americans safe
ok inside one of the overflow facilities for migrant children in Donna, Texas. The images were provided to NBC News with faces already obscured" by Cuellar, who 'would not say who took the pictures, only that they were taken this past weekend: Cuellar "I think the public needs to know the conditions of
, Kight, 1.26M) on Monday morning. Psaki was asked on CNN's The Lead (3/22, 1.1M) if the President believes the conditions in the photos released by Cuellar are acceptable. Psaki said, "No, he doesn't, and that's why he wants to move children as quickly as possible out of the Border Patrol facilities. T
e 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, courts, including the Eleventh Circuit in Evans, have underscored the point that § 1591 simp
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
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 →he Evans co-defendants makes clear. See, United States v. Madison, 477 F.3d 1312, 1313-1314 (1 14 Cir. 2007) (Jane Doe #2 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
Page: HOUSE_OVERSIGHT_012196 →Entities connected to both Atlanta and Cuellar

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Lesley Groff
PERSON
United States
LOCATIONLeon Black
PERSON
Virginia Giuffre
PERSON
Marc Rich
PERSON
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Bill Clinton
PERSON
Michigan
LOCATION
Woody Allen
PERSON
Chris Tucker
PERSON
Mike Pence
PERSON
Barry Diller
PERSON
Supreme Court
ORGANIZATIONthe Southern District
LOCATION
Alexander Acosta
PERSONJane Doe
PERSON
Palm Beach
LOCATION