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Extraction Summary
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People
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Locations
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Events
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Quotes
Document Information
Type:
Legal document
File Size:
624 KB
Summary
This legal document, part of Case 22-1426, details an argument by the defendant, Maxwell, that charges of Sex Trafficking Conspiracy and Sex Trafficking are time-barred under the general five-year statute of limitations. The document outlines the history of relevant legislation, including the PROTECT Act of 2003 and 18 U.S.C. § 3299, which extended or eliminated limitations for such crimes. Maxwell contends these extensions do not apply to her specific charges, renewing a previously argued position, because the alleged conduct occurred between 2001 and 2004.
People (1)
| Name | Role | Context |
|---|---|---|
| Maxwell | Defendant |
Mentioned throughout the document as the individual arguing that charges against her are time-barred.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| Congress | government agency |
Mentioned as the legislative body that has enacted and extended statutes of limitations for certain crimes.
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| The Court | government agency |
Mentioned as having denied a previous motion by Maxwell.
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| The Government | government agency |
Mentioned as the prosecuting party that has brought new charges against Maxwell.
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Timeline (4 events)
Relationships (1)
The document describes a legal dispute where the Government is prosecuting Maxwell, and Maxwell is filing motions to argue that the charges are time-barred.
Key Quotes (3)
"offense[s] involving the sexual or physical abuse, or kidnapping"Source
— 18 U.S.C. § 3283
(Describing the types of crimes for which Congress has enacted longer limitations periods.)
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Quote #1
"Notwithstanding any other law, an indictment may be found or an information instituted at any time without limitation for any offense under . . . section 1591."Source
— 18 U.S.C. § 3299
(Quoted to show that the statute of limitations was eliminated for sex trafficking of minors.)
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Quote #2
"necessarily entail"Source
— Maxwell
(Part of Maxwell's argument that the extended limitations period only applies to offenses that inherently involve the sexual abuse of a minor.)
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,113 characters)
Case 22-1426, Document 57, 02/28/2023, 3475900, Page198 of 208
A-194
A-194
III. Counts five and six are not time-barred
For most non-capital offenses, the statute of limitations under federal law is five years.
18 U.S.C. § 3282(a). Congress has enacted longer limitations periods for certain crimes, in
particular for “offense[s] involving the sexual or physical abuse, or kidnapping” of a minor in 18
U.S.C. § 3283. Prior to 2003, the limitations period in § 3283 lasted until the victim reached the
age of 25, and then Congress extended the limitations period to the life of the victim with the
PROTECT Act of 2003, Pub. L. No. 108-21, 117 Stat 60. In 2006, Congress enacted 18 U.S.C.
§ 3299, which eliminated the statute of limitations for the sex trafficking of minors in violation
of 18 U.S.C. § 1591 and for some other sex crimes. See 18 U.S.C. § 3299 (“Notwithstanding
any other law, an indictment may be found or an information instituted at any time without
limitation for any offense under . . . section 1591.”).
18 U.S.C. § 3282(a). Congress has enacted longer limitations periods for certain crimes, in
particular for “offense[s] involving the sexual or physical abuse, or kidnapping” of a minor in 18
U.S.C. § 3283. Prior to 2003, the limitations period in § 3283 lasted until the victim reached the
age of 25, and then Congress extended the limitations period to the life of the victim with the
PROTECT Act of 2003, Pub. L. No. 108-21, 117 Stat 60. In 2006, Congress enacted 18 U.S.C.
§ 3299, which eliminated the statute of limitations for the sex trafficking of minors in violation
of 18 U.S.C. § 1591 and for some other sex crimes. See 18 U.S.C. § 3299 (“Notwithstanding
any other law, an indictment may be found or an information instituted at any time without
limitation for any offense under . . . section 1591.”).
In her previous motion, Maxwell argued that the Mann Act charges against her in the
indictment were time-barred on the grounds that the extended limitations period § 3283 was not
applicable. The Court denied that motion in its April 16, 2021 Opinion & Order. Maxwell, 2021
WL 1518675, at *5. Maxwell now argues that the new charges the Government has brought
against her in the S2 indictment, Sex Trafficking Conspiracy (18 U.S.C. § 371) and Sex
Trafficking (18 U.S.C. § 1591), are time-barred as well because § 3283 does not apply to those
offenses either. She renews her contention from her previous motion that the limitations period
in § 3283 only applies to offenses which “necessarily entail” the sexual abuse of a minor and
argues that a violation of 18 U.S.C. § 1591 does not. Thus, according to Maxwell’s reasoning,
the general five-year statute of limitations period in 18 U.S.C. § 3282(a) applies to the sex
trafficking counts and, because the alleged conduct occurred from 2001 to 2004, the Government
is now time-barred for prosecuting her for these offenses.
indictment were time-barred on the grounds that the extended limitations period § 3283 was not
applicable. The Court denied that motion in its April 16, 2021 Opinion & Order. Maxwell, 2021
WL 1518675, at *5. Maxwell now argues that the new charges the Government has brought
against her in the S2 indictment, Sex Trafficking Conspiracy (18 U.S.C. § 371) and Sex
Trafficking (18 U.S.C. § 1591), are time-barred as well because § 3283 does not apply to those
offenses either. She renews her contention from her previous motion that the limitations period
in § 3283 only applies to offenses which “necessarily entail” the sexual abuse of a minor and
argues that a violation of 18 U.S.C. § 1591 does not. Thus, according to Maxwell’s reasoning,
the general five-year statute of limitations period in 18 U.S.C. § 3282(a) applies to the sex
trafficking counts and, because the alleged conduct occurred from 2001 to 2004, the Government
is now time-barred for prosecuting her for these offenses.
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