{
  "document_metadata": {
    "page_number": "8",
    "document_number": "317",
    "date": "08/13/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 317 Filed 08/13/21 Page 8 of 14\n\nThe Court denies this motion for substantially similar reasons as those discussed in its April 16, 2021 Opinion & Order. As an initial matter, the Court reiterates that Maxwell's analysis of § 3283 is incorrect. As the Court explained, § 3283 does not call for a \"categorical approach\" nor an \"essential ingredient\" test, but instead requires that the defendant's conduct in that particular case involved the sexual abuse of a minor. Maxwell, 2021 WL 1518675 at *5-7. Here, there is no question that Maxwell is alleged to have engaged in activity that constitutes the sexual abuse of a minor with respect to the sex trafficking counts.\n\nBut in any event, as the Government pointed out in its brief - and as Maxwell did not contest in her reply - § 3283 is not the only statute of limitations that applies to the sex trafficking counts. As discussed above, in 2006, Congress enacted § 3299 to eliminate altogether the limitations period for the offense of sex trafficking children in violation of § 1591. See 18 U.S.C. § 3299.\n\nMoreover, while the alleged sex trafficking in the S2 indictment is alleged to have occurred prior to the enactment of § 3299 in 2006, the Court holds that the provision nonetheless applies retroactively to cover that conduct. In its April 16, 2021 Opinion & Order, the Court analyzed § 3283 under the Landgraf v. USA Film Products, 511 U.S. 244, 280 (1994) framework and concluded that the limitations period applied retroactively so long as the previous limitations period had not yet expired. Maxwell, 2021 WL 1518675, at *7-8. Similar to § 3283, which states that \"[n]o statute of limitations that would otherwise preclude prosecution\" shall apply, the language of § 3299 provides that an indictment may be instituted at any time for certain offenses \"[n]otwithstanding any other law.\" As discussed in the Court's previous opinion with respect to § 3283, this kind of language unambiguously requires that the limitations period apply retroactively to prosecutions for offenses committed before the date of enactment so long as the\n\n8\n\nDOJ-OGR-00004982",
  "text_blocks": [
    {
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      "content": "Case 1:20-cr-00330-PAE Document 317 Filed 08/13/21 Page 8 of 14",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Court denies this motion for substantially similar reasons as those discussed in its April 16, 2021 Opinion & Order. As an initial matter, the Court reiterates that Maxwell's analysis of § 3283 is incorrect. As the Court explained, § 3283 does not call for a \"categorical approach\" nor an \"essential ingredient\" test, but instead requires that the defendant's conduct in that particular case involved the sexual abuse of a minor. Maxwell, 2021 WL 1518675 at *5-7. Here, there is no question that Maxwell is alleged to have engaged in activity that constitutes the sexual abuse of a minor with respect to the sex trafficking counts.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "But in any event, as the Government pointed out in its brief - and as Maxwell did not contest in her reply - § 3283 is not the only statute of limitations that applies to the sex trafficking counts. As discussed above, in 2006, Congress enacted § 3299 to eliminate altogether the limitations period for the offense of sex trafficking children in violation of § 1591. See 18 U.S.C. § 3299.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Moreover, while the alleged sex trafficking in the S2 indictment is alleged to have occurred prior to the enactment of § 3299 in 2006, the Court holds that the provision nonetheless applies retroactively to cover that conduct. In its April 16, 2021 Opinion & Order, the Court analyzed § 3283 under the Landgraf v. USA Film Products, 511 U.S. 244, 280 (1994) framework and concluded that the limitations period applied retroactively so long as the previous limitations period had not yet expired. Maxwell, 2021 WL 1518675, at *7-8. Similar to § 3283, which states that \"[n]o statute of limitations that would otherwise preclude prosecution\" shall apply, the language of § 3299 provides that an indictment may be instituted at any time for certain offenses \"[n]otwithstanding any other law.\" As discussed in the Court's previous opinion with respect to § 3283, this kind of language unambiguously requires that the limitations period apply retroactively to prosecutions for offenses committed before the date of enactment so long as the",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "8",
      "position": "footer"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00004982",
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  ],
  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [
      "USA Film Products",
      "Congress",
      "Court",
      "Government"
    ],
    "locations": [],
    "dates": [
      "April 16, 2021",
      "08/13/21",
      "2006",
      "1994"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 317",
      "§ 3283",
      "§ 3299",
      "§ 1591",
      "18 U.S.C. § 3299",
      "511 U.S. 244",
      "2021 WL 1518675"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Maxwell, with discussions on statutes of limitations and their application to sex trafficking counts. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and legible."
}