EFTA00028903.pdf
1.28 MB
Extraction Summary
7
People
6
Organizations
2
Locations
1
Events
4
Relationships
4
Quotes
Document Information
Type:
Legal memorandum (reply memorandum in support of motion to dismiss)
File Size:
1.28 MB
Summary
This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on March 15, 2021, supporting a motion to dismiss counts one through four of her indictment as time-barred. The defense argues that the 2003 Amendment to 18 U.S.C. § 3283, which extended the statute of limitations, cannot be applied retroactively because Congress explicitly rejected a retroactivity provision. Additionally, the defense contends that the Mann Act offenses charged (enticement to travel and transportation of a minor) do not 'necessarily entail' the sexual abuse of a child, and thus the extended statute of limitations under § 3283 does not apply.
People (7)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Filing a reply memorandum in support of her motion to dismiss counts one through four of the superseding indictment a...
|
| Christian R. Everdell | Attorney |
Attorney for Ghislaine Maxwell, Cohen & Gresser LLP.
|
| Jeffrey S. Pagliuca | Attorney |
Attorney for Ghislaine Maxwell, Haddon, Morgan & Foreman P.C.
|
| Laura A. Menninger | Attorney |
Attorney for Ghislaine Maxwell, Haddon, Morgan & Foreman P.C.
|
| Bobbi C. Sternheim | Attorney |
Attorney for Ghislaine Maxwell, Law Offices of Bobbi C. Sternheim.
|
| Senator Leahy | Politician |
Cited in legislative history regarding the Amber Legislation and the 2003 Amendment.
|
| AJN | Judge |
Presiding judge (initials in case number 20 Cr. 330).
|
Timeline (1 events)
2021-03-15
Filing of Reply Memorandum of Ghislaine Maxwell
New York, New York
Locations (2)
| Location | Context |
|---|---|
Relationships (4)
Listed as Attorney for Ghislaine Maxwell on the signature page.
Listed as Attorney for Ghislaine Maxwell on the signature page.
Listed as Attorney for Ghislaine Maxwell on the signature page.
Listed as Attorney for Ghislaine Maxwell on the signature page.
Key Quotes (4)
"The 2003 Amendment Does Not Apply Retroactively."Source
EFTA00028903.pdf
Quote #1
"Congress' explicit rejection of a retroactivity provision ends the inquiry at step one in Ms. Maxwell's favor."Source
EFTA00028903.pdf
Quote #2
"Neither enticement of an individual to travel nor transportation of a minor is an 'offense involving' the sexual or physical abuse or kidnapping of a child."Source
EFTA00028903.pdf
Quote #3
"If a defendant entices an adult to travel for the purpose of engaging in unlawful sexual activity, a § 2422(a) offense has been committed, but no sexual abuse of a child has occurred."Source
EFTA00028903.pdf
Quote #4
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