mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00021703.json

{
  "document_metadata": {
    "page_number": "56",
    "document_number": "79",
    "date": "06/29/2023",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 22-1426, Document 79, 06/29/2023, 3536060, Page56 of 93\n43\nin fact sexually abused when transported across state lines, including to New York, as a minor. Instead, Maxwell insists that Counts Three and Four do not involve sexual abuse of a child because a completed sex act is not an element of those crimes. This argument misreads the relevant statutes and legislative history, and runs contrary to the decisions of this Court and other Courts of Appeals.11\na. Counts Three and Four Are Offenses Involving the Sexual Abuse of a Child\nMaxwell's entire argument is based on a mistaken premise: that the phrase \"offense involving the sexual . . . abuse . . . of a child,\" 18 U.S.C. § 3283, only encompasses crimes in which \"unlawful sexual activity actually took place.\" (Br.44). This flawed proposition ignores relevant statutory definitions, which make clear that Section 3283 reaches more broadly to include offenses in which there was no completed illegal sex act.\nAs described above, Section 3283 was originally codified at 18 U.S.C. § 3509(k). The definition of the term \"sexual abuse\" is located within that same section:\nFor purposes of this section . . . the term 'sexual abuse' includes the employment, use, persuasion, inducement, enticement,\n11 Maxwell raises no analogous argument with respect to Count Six, which charges sex trafficking of a minor, in violation of 18 U.S.C. § 1591.\nDOJ-OGR-00021703",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 22-1426, Document 79, 06/29/2023, 3536060, Page56 of 93",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "43\nin fact sexually abused when transported across state lines, including to New York, as a minor. Instead, Maxwell insists that Counts Three and Four do not involve sexual abuse of a child because a completed sex act is not an element of those crimes. This argument misreads the relevant statutes and legislative history, and runs contrary to the decisions of this Court and other Courts of Appeals.11\na. Counts Three and Four Are Offenses Involving the Sexual Abuse of a Child\nMaxwell's entire argument is based on a mistaken premise: that the phrase \"offense involving the sexual . . . abuse . . . of a child,\" 18 U.S.C. § 3283, only encompasses crimes in which \"unlawful sexual activity actually took place.\" (Br.44). This flawed proposition ignores relevant statutory definitions, which make clear that Section 3283 reaches more broadly to include offenses in which there was no completed illegal sex act.\nAs described above, Section 3283 was originally codified at 18 U.S.C. § 3509(k). The definition of the term \"sexual abuse\" is located within that same section:\nFor purposes of this section . . . the term 'sexual abuse' includes the employment, use, persuasion, inducement, enticement,",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "11 Maxwell raises no analogous argument with respect to Count Six, which charges sex trafficking of a minor, in violation of 18 U.S.C. § 1591.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00021703",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [
      "Court",
      "Courts of Appeals"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "06/29/2023"
    ],
    "reference_numbers": [
      "Case 22-1426",
      "Document 79",
      "18 U.S.C. § 3283",
      "18 U.S.C. § 3509(k)",
      "18 U.S.C. § 1591",
      "DOJ-OGR-00021703"
    ]
  },
  "additional_notes": "The document appears to be a court document, likely a legal brief or memorandum, discussing the case of Maxwell. The text is printed, with no visible handwriting or stamps. The document includes references to specific statutes and court decisions."
}