📧 Communication

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.