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Extraction Summary

2
People
5
Organizations
2
Locations
2
Events
1
Relationships
5
Quotes

Document Information

Type: Legal filing / court document (government response)
File Size: 683 KB
Summary

This document is page 23 of a government filing in the case against Ghislaine Maxwell, arguing against her motions to dismiss. The prosecution asserts that the Non-Prosecution Agreement (NPA) from the Southern District of Florida does not apply to the current indictment or district, and denies her request for discovery due to lack of evidence. Furthermore, the document argues that the indictment is timely under 18 U.S.C. § 3283 because the statute allows prosecution for child sexual abuse offenses as long as the victims are alive, rejecting Maxwell's argument that the statute applies only prospectively.

People (2)

Name Role Context
Ghislaine Maxwell Defendant
Referenced as 'Maxwell' and 'the defendant'; the document argues against her motions regarding the NPA and statute of...
Urena Case Citation Subject
Referenced in case law 'United States v. Urena'.

Organizations (5)

Name Type Context
USAO-SDFL
United States Attorney's Office for the Southern District of Florida; mentioned regarding promises allegedly made in ...
OPR
Office of Professional Responsibility; mentioned regarding an investigation surrounding the NPA.
Congress
Mentioned regarding the legislative intent of the statute of limitations extension.
S.D.N.Y.
Southern District of New York; mentioned in case citation and implied as 'this District'.
DOJ
Department of Justice; appears in the footer stamp (DOJ-OGR).

Timeline (2 events)

2003
Amendment of 18 U.S.C. § 3283
US
Prior to 2021
OPR Investigation and Civil Litigation
Unknown

Locations (2)

Location Context
Associated with the USAO-SDFL and the original NPA.
Implied as 'this District' where the current indictment is held.

Relationships (1)

Ghislaine Maxwell Legal/Adversarial USAO-SDFL
Maxwell claims USAO-SDFL made promises in the NPA; the document refutes this applies to the current case.

Key Quotes (5)

"claiming that the USAO-SDFL made promises that were not contained in the NPA."
Source
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Quote #1
"In the absence of any such evidence—and in the face of substantial contrary evidence gathered in the civil litigation and OPR investigation—the Court has no obligation to conduct a hearing."
Source
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Quote #2
"A defendant seeking discovery under Rule 16 “must make a prima facie showing of materiality and must offer more than the conclusory allegation that the requested evidence is material.”"
Source
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Quote #3
"Counts One through Four are timely charged because the applicable limitations period, 18 U.S.C. § 3283 (2003), permits prosecution for offenses “involving the sexual or physical abuse… of a child” at any time “during the life of the child,” and each of the victims identified in the Indictment remains alive."
Source
DOJ-OGR-00002984.jpg
Quote #4
"In effect, the defendant’s motion asks this Court to break new ground, and become the first court to hold that Section 3283 applies only prospectively."
Source
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Quote #5

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