{
  "document_metadata": {
    "page_number": "50",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 50 of 239 claiming that the USAO-SDFL made promises that were not contained in the NPA. Nor has she pointed to anything in the extensive record of either the OPR investigation or the civil litigation surrounding the NPA that would suggest that the NPA applies to this District, or to the crimes in the Indictment, or to Maxwell. In the absence of any such evidence—and in the face of substantial contrary evidence gathered in the civil litigation and OPR investigation—the Court has no obligation to conduct a hearing. For similar reasons, the defendant’s motion for discovery should be denied. To the extent the defendant seeks discovery under Rule 16, she has failed to meet her burden. A defendant seeking discovery under Rule 16 “must make a prima facie showing of materiality and must offer more than the conclusory allegation that the requested evidence is material.” United States v. Urena, 989 F. Supp. 2d 253, 261 (S.D.N.Y. 2013) (citations omitted). Here, the defendant has offered nothing more than her conjecture that some unspecified evidence might exist. The motion should be denied. II. The Indictment Is Timely Counts One through Four are timely charged because the applicable limitations period, 18 U.S.C. § 3283 (2003), permits prosecution for offenses “involving the sexual or physical abuse… of a child” at any time “during the life of the child,” and each of the victims identified in the Indictment remains alive. Maxwell contends that Section 3283 should not be applied to conduct that predated its amendment in 2003 (Def. Mot. 2), but that argument is contrary to the text of the statute, Congress’s clear intent when extending the statute of limitations, and the decisions of other circuits and district courts in this Circuit. In effect, the defendant’s motion asks this Court to break new ground, and become the first court to hold that Section 3283 applies only prospectively. 23 DOJ-OGR-00002984",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 50 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "claiming that the USAO-SDFL made promises that were not contained in the NPA. Nor has she pointed to anything in the extensive record of either the OPR investigation or the civil litigation surrounding the NPA that would suggest that the NPA applies to this District, or to the crimes in the Indictment, or to Maxwell. In the absence of any such evidence—and in the face of substantial contrary evidence gathered in the civil litigation and OPR investigation—the Court has no obligation to conduct a hearing. For similar reasons, the defendant’s motion for discovery should be denied. To the extent the defendant seeks discovery under Rule 16, she has failed to meet her burden. A defendant seeking discovery under Rule 16 “must make a prima facie showing of materiality and must offer more than the conclusory allegation that the requested evidence is material.” United States v. Urena, 989 F. Supp. 2d 253, 261 (S.D.N.Y. 2013) (citations omitted). Here, the defendant has offered nothing more than her conjecture that some unspecified evidence might exist. The motion should be denied.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "II. The Indictment Is Timely Counts One through Four are timely charged because the applicable limitations period, 18 U.S.C. § 3283 (2003), permits prosecution for offenses “involving the sexual or physical abuse… of a child” at any time “during the life of the child,” and each of the victims identified in the Indictment remains alive. Maxwell contends that Section 3283 should not be applied to conduct that predated its amendment in 2003 (Def. Mot. 2), but that argument is contrary to the text of the statute, Congress’s clear intent when extending the statute of limitations, and the decisions of other circuits and district courts in this Circuit. In effect, the defendant’s motion asks this Court to break new ground, and become the first court to hold that Section 3283 applies only prospectively.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "23",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002984",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [
      "USAO-SDFL",
      "OPR",
      "Congress",
      "Court"
    ],
    "locations": [
      "District",
      "S.D.N.Y.",
      "Circuit"
    ],
    "dates": [
      "04/16/21",
      "2003"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 204",
      "18 U.S.C. § 3283",
      "DOJ-OGR-00002984"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case against Maxwell. The text discusses the defendant's motion for discovery and the timeliness of the indictment. The document is well-formatted and free of significant damage or redactions."
}