{
  "document_metadata": {
    "page_number": "62",
    "document_number": "59",
    "date": "02/28/2023",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 22-1426, Document 59, 02/28/2023, 3475902, Page62 of 113\nalternative holding — \"[a] further ground for [its] conclusion\" —that, even in cases where “fraud” occurs, a categorical analysis precludes extending the WSLA to prosecutions for making false statements. Id. at 221-22. And in applying this categorical approach, Bridges looked, not to the legislative history of the WSLA, but to Scharton and Noveck (which involved a different statute). See Bridges, 346 U.S. at 222 (citing, inter alia, Scharton and Noveck).\n\nHere, Bridges, Scharton, and Noveck point the way. Because § 3283 employs the same “offense-involving” language as the statutes analyzed in those cases, compare 18 U.S.C. § 3283 with id. § 3287; 26 U.S.C. § 6531, a similar interpretation should govern. See Smith v. City of Jackson, Miss., 544 U.S. 228, 233 (2005); Wasser v. New York State Off. of Vocational & Educational Servs., 602 F.3d 476, 480 (2d Cir. 2010). The Court should apply a categorical approach and hold that § 3283 did not modify the statute of limitations for § 2423(a) violations.\n\nNothing in the text of § 3283 indicates a contrary result. Indeed, Congress has shown that when it wants to tether a statute of limitations to conduct occurring in a particular case, it knows how to do so—and uses unambiguous wording distinct from § 3283. Notably, in 2001, Congress eliminated the statute of limitations for certain terrorism offenses in which “the commission of such offense resulted in, or created a foreseeable risk of, death or serious bodily injury to",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 22-1426, Document 59, 02/28/2023, 3475902, Page62 of 113\nalternative holding — \"[a] further ground for [its] conclusion\" —that, even in cases where “fraud” occurs, a categorical analysis precludes extending the WSLA to prosecutions for making false statements. Id. at 221-22. And in applying this categorical approach, Bridges looked, not to the legislative history of the WSLA, but to Scharton and Noveck (which involved a different statute). See Bridges, 346 U.S. at 222 (citing, inter alia, Scharton and Noveck).\n\nHere, Bridges, Scharton, and Noveck point the way. Because § 3283 employs the same “offense-involving” language as the statutes analyzed in those cases, compare 18 U.S.C. § 3283 with id. § 3287; 26 U.S.C. § 6531, a similar interpretation should govern. See Smith v. City of Jackson, Miss., 544 U.S. 228, 233 (2005); Wasser v. New York State Off. of Vocational & Educational Servs., 602 F.3d 476, 480 (2d Cir. 2010). The Court should apply a categorical approach and hold that § 3283 did not modify the statute of limitations for § 2423(a) violations.\n\nNothing in the text of § 3283 indicates a contrary result. Indeed, Congress has shown that when it wants to tether a statute of limitations to conduct occurring in a particular case, it knows how to do so—and uses unambiguous wording distinct from § 3283. Notably, in 2001, Congress eliminated the statute of limitations for certain terrorism offenses in which “the commission of such offense resulted in, or created a foreseeable risk of, death or serious bodily injury to",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "47",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00021109",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [],
    "locations": [
      "New York"
    ],
    "dates": [
      "02/28/2023",
      "2001",
      "2005",
      "2010"
    ],
    "reference_numbers": [
      "22-1426",
      "59",
      "3475902",
      "62",
      "113",
      "221-22",
      "222",
      "3283",
      "3287",
      "6531",
      "228",
      "233",
      "476",
      "480",
      "2423(a)",
      "DOJ-OGR-00021109"
    ]
  },
  "additional_notes": "The document appears to be a court document, likely a brief or memorandum, discussing the application of statutes of limitations to certain offenses. The text is printed and there are no visible stamps or handwritten annotations. The document is well-formatted and legible."
}