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Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 65 of 239

broad definition, courts have held that Section 3283 “does not require that an offense consist of a sexual act between a defendant and a specific child,” Vickers, 2014 WL 1838255, at *11, but instead reaches offenses involving the transportation of minors to engage in illegal sexual activity. See Sensi, 2010 WL 2351484, at *2-3 (collecting cases interpreting the term “sexual abuse” to encompass “all crimes that would logically relate to the common understanding of sexual abuse even when found in chapters 110 (‘Sexual Exploitation and Other Abuse of Children’) and 117 (‘Transportation of Illegal Sexual Activity and Related Crimes’) of title 18”); Schneider, 801 F.3d at 196-97 (holding that Section 3283 applied to defendant convicted of traveling with the purpose of engaging in sex with a minor victim, in violation of 18 U.S.C. § 2423(b)); Vickers, 2014 WL 1838255, at *11-12 (holding that violations of 18 U.S.C. § 2423(a) were crimes involving sexual abuse under Section 3283).
The defendant’s motion does not engage with these authorities at all. Instead, the defendant asks the Court to apply an “essential ingredients” test, relying heavily upon the Supreme Court’s decision in Bridges v. United States, 346 U.S. 209 (1953), which concerned the Wartime Suspension of Limitations Act (“WSLA”). (Def. Mot. 2 at 12-14). But Bridges is inapposite, since it concerned a statute “[t]he legislative history of [which] emphasize[d] the propriety of its conservative interpretation” and “indicate[d] a purpose to suspend the general statute of limitations only as to” certain narrowly defined offenses. Bridges, 346 U.S. at 216. There is no corresponding indication that Congress intended the “essential ingredients” test to apply to Section 3283. As the Third Circuit has explained in rejecting an identical argument:

While Bridges did adopt an “essential ingredient” test, the limitations-extending statute at issue was a narrowly drafted exception specifically intended to target frauds related to war procurement. Unlike the WSLA, § 3283 has no such restrictive language or legislative history suggesting congressional intent to limit its application to a specific subset of circumstances. Congress,

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