mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00021688.json

{
  "document_metadata": {
    "page_number": "41",
    "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, Page41 of 93\n28\nidentifies no evidence that the Department of Justice made any promises not contained in the NPA.\" (A.142-43). Here, as below, Maxwell's further request for a hearing \"rests on mere conjecture.\" (A.145). Judge Nathan did not abuse her discretion.\n\nPOINT II\nThe District Court Correctly Concluded that the Charges Were Timely\nIn 2003, Congress extended the statute of limitations for \"offense[s] involving the sexual or physical abuse\" of a minor to allow prosecution so long as the victim remains alive. 18 U.S.C. § 3283. Attempting to undermine the clear legislative intent, Maxwell argues that the amendment did not apply to her case because her crimes both pre-dated the amendment and did not involve sexual abuse. These arguments fly in the face of the statutory text, legislative history, this Court's own decisions, and the persuasive authority of other Circuits. The charges fell squarely within the amended statute of limitations, and this Court should affirm Judge Nathan's well-reasoned decisions denying Maxwell's motions to dismiss the charges as untimely.\n\nA. Applicable Law\n\n1. Standard of Review\nThis Court reviews de novo both the denial of a motion to dismiss an indictment and the application of a statute of limitations. United States v. Sampson, 898 F.3d 270, 276, 278 (2d Cir. 2018).\n\nDOJ-OGR-00021688",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 22-1426, Document 79, 06/29/2023, 3536060, Page41 of 93",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "28\nidentifies no evidence that the Department of Justice made any promises not contained in the NPA.\" (A.142-43). Here, as below, Maxwell's further request for a hearing \"rests on mere conjecture.\" (A.145). Judge Nathan did not abuse her discretion.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "POINT II\nThe District Court Correctly Concluded that the Charges Were Timely",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In 2003, Congress extended the statute of limitations for \"offense[s] involving the sexual or physical abuse\" of a minor to allow prosecution so long as the victim remains alive. 18 U.S.C. § 3283. Attempting to undermine the clear legislative intent, Maxwell argues that the amendment did not apply to her case because her crimes both pre-dated the amendment and did not involve sexual abuse. These arguments fly in the face of the statutory text, legislative history, this Court's own decisions, and the persuasive authority of other Circuits. The charges fell squarely within the amended statute of limitations, and this Court should affirm Judge Nathan's well-reasoned decisions denying Maxwell's motions to dismiss the charges as untimely.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "A. Applicable Law\n\n1. Standard of Review",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "This Court reviews de novo both the denial of a motion to dismiss an indictment and the application of a statute of limitations. United States v. Sampson, 898 F.3d 270, 276, 278 (2d Cir. 2018).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00021688",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Nathan"
    ],
    "organizations": [
      "Department of Justice",
      "Congress",
      "Court"
    ],
    "locations": [],
    "dates": [
      "2003",
      "06/29/2023"
    ],
    "reference_numbers": [
      "22-1426",
      "79",
      "3536060",
      "DOJ-OGR-00021688",
      "18 U.S.C. § 3283",
      "898 F.3d 270",
      "A.142-43",
      "A.145"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Maxwell. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and legible."
}