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611 KB

Extraction Summary

6
People
3
Organizations
0
Locations
2
Events
1
Relationships
3
Quotes

Document Information

Type: Legal document
File Size: 611 KB
Summary

This document is a handwritten legal argument filed in court on October 12, 2021, challenging a court's interpretation of statute §3283. The author argues that the statute's legislative history, originating from the 1986 Sexual Abuse Act, demonstrates its narrow purpose is for sexual assault and related offenses, not a broader application. The argument cites several legal cases (Davis, Pledges, Bridges) to contend that the court's findings are 'patently wrong'.

People (6)

Name Role Context
Davis
Referenced in a Supreme Court case, 'In Davis (see brief) the Supreme Court found...'
Pledges
Referenced in a SORNA case, '...no reason to use Pledges (SORNA)...'
Bridges
Referenced in a case involving fraud, '...to difference Bridges (offense involving fraud)...'
Morgan
Cited from Maxwell's brief, 'Morgan (cited from Maxwell's brief) is highly relevant...'
Maxwell
Author of a brief from which Morgan is cited, '...Morgan (cited from Maxwell's brief)...'
Toussic V
Referenced as a legal case citation, 'See Toussic V.'

Organizations (3)

Name Type Context
Congress government agency
Mentioned in relation to the legislative history of §3283: '...goes far beyond Congress raising the limitation period...
Supreme Court government agency
Mentioned as having made a finding in the Davis case: 'In Davis (see brief) the Supreme Court found...'
the government government agency
Mentioned in a parenthetical comment: '(not that the government would have any respect for truth)'

Timeline (2 events)

1986
The legislative history of §3283 originates from the 1986 Sexual Abuse Act.
2021-10-12
Filing of Document 338 in Case 1:20-cr-00330-PAE.

Relationships (1)

Morgan professional Maxwell
The document states 'Morgan (cited from Maxwell's brief)', indicating that Morgan's legal arguments are referencing or relying on those made by Maxwell in a separate brief.

Key Quotes (3)

"conduct involved"
Source
— The Court (in its opinion) (Cited as an incorrect interpretation of §3283 by the court, contrasted with the actual text.)
DOJ-OGR-00005182.jpg
Quote #1
"offense involving"
Source
— Statute §3283 (Presented as the actual wording of the statute, which the author argues requires a 'statutory elements inquiry'.)
DOJ-OGR-00005182.jpg
Quote #2
"no other statute of limitation shall preclude..."
Source
— Section 3283 (Quoted to argue that the statute supersedes other statutes of limitations but does not extend prior versions of itself.)
DOJ-OGR-00005182.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,186 characters)

Case 1:20-cr-00330-PAE Document 338 Filed 10/12/21 Page 4 of 22
The legislative history of §3283 goes far beyond Congress raising the limitation period, and actually originates from the 1986 Sexual Abuse Act.
This Court's findings are patently wrong. For example §3283 doesn't say, "conduct involved" (brackets in opinion), its "offense involving." In Davis (see brief) the Supreme Court found the later most probably requires a statutory elements inquiry. There is also no reason to use Pledges (SORNA) to difference Bridges (offense involving fraud), because in fact the legislative history of §3283 does show the narrow purpose of §3283. Further-more, Morgan (cited from Maxwell's brief) is highly relevant, regardless whether Venue is the subject. Why would that have relevance?
Section 3283's "no other statute of limitation shall preclude..." is not intended to extend prior versions of §3283; that is in fact ridiculous. §3283 superceeds other statutes of limitations. See brief.
The truth (not that the government would have any respect for truth) is §3283 is for sexual assault and other enclave offenses. §3299 covers sex related offenses. See Toussic V.
4
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