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563 KB
Extraction Summary
4
People
2
Organizations
1
Locations
2
Events
1
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
563 KB
Summary
This legal document argues that a 2003 amendment to Section 3283, which extended a statute of limitations, was properly applied to Maxwell's case under the 'Landgraf' legal framework. It contends that since the original limitations period had not expired when Congress passed the amendment, the charges against Maxwell are timely. The document also cites evidence from a separate case (United States v. Rutigliano) showing that an individual named Carolyn visited Epstein's residence through 2004, establishing a relevant timeline.
People (4)
| Name | Role | Context |
|---|---|---|
| Maxwell | Subject of prosecution |
Mentioned in the context of arguments about the statute of limitations for charges against her, specifically regardin...
|
| Carolyn |
Mentioned as someone who continued to visit Epstein's residence through 2004, as established by evidence at trial in ...
|
|
| Epstein |
Mentioned as the owner of a residence that Carolyn visited through 2004.
|
|
| Rutigliano | Defendant in a cited case |
Mentioned in the case citation 'United States v. Rutigliano, 790 F.3d 389, 400 (2d Cir. 2015)'.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Congress | Government agency |
Mentioned as the body that enacted the 2003 amendment to Section 3283.
|
| District Court | Judicial body |
Mentioned as having summarized evidence at sentencing in the Rutigliano case.
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Locations (1)
| Location | Context |
|---|---|
|
Mentioned as a place Carolyn continued to visit through 2004.
|
Key Quotes (1)
"expressly prescribed the statute’s proper reach."Source
— Landgraf (case)
(Quoted from the Landgraf case (511 U.S. at 280) as the key question for step one of the Landgraf analysis regarding Congress's intent.)
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Quote #1
Full Extracted Text
Complete text extracted from the document (1,320 characters)
Case 22-1426, Document 79, 06/29/2023, 3536060, Page46 of 93
33
of limitations for these two counts did not begin to run until 2004, well after Congress enacted the 2003 amendment to Section 3283. Maxwell’s arguments about retroactivity are therefore inapplicable to Counts Three and Six.
b. Applying Section 3283 to Maxwell Complies with Landgraf
Furthermore, under the Landgraf framework, the 2003 amendment to Section 3283 properly applies to pre-enactment conduct for which the statute of limitations had not expired at the time the amendment was passed. Because the statute of limitations had not expired when Congress amended Section 3283 in 2003, that amendment extended the limitations period for prosecuting Maxwell, rendering the charges timely.
i. Landgraf Step One
At step one of the Landgraf analysis, the question is whether Congress has “expressly prescribed the statute’s proper reach.” Landgraf, 511 U.S. at 280. When evaluating Congress’s intent at step one, this
of the motions to dismiss, see United States v. Rutigliano, 790 F.3d 389, 400 (2d Cir. 2015), the evidence at trial established that Carolyn continued to visit Epstein’s residence through 2004. (Tr.1525, 1548-49; GX-1B; GX-3D through K; see also SA406-07 (District Court summarizing such evidence at sentencing)).
DOJ-OGR-00021693
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