EFTA00028903.pdf

"UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. 20 Cr. 330 (AJN)"

"UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, 20 Cr. 330 (AJN)"

"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK 20 Cr. 330 (AJN)"

"Christian R. Everdell COHEN & GRESSER LLP Attorneysfor Ghislaine Maxwell"

"Jeffrey S. Pagliuca HADDON, MORGAN & FOREMAN P.C. Attorneysfor Ghislaine Maxwell"

"Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Attorneysfor Ghislaine Maxwell"

"Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneysfor Ghislaine Maxwell"

"Christian R. Everdell COHEN & GRESSER LLP"

"Ms. Maxwell's Motion should be granted for the separate and independent reason that § 3283 does not apply to 18 U.S.C. § 2422(a) or 18 U.S.C. § 2423(a"

"Ms. Maxwell's Motion should be granted for the separate and independent reason that § 3283 does not apply to 18 U.S.C. § 2422(a) or 18 U.S.C. § 2423(a"

"Counts One through Four are therefore time-barred. ... Ms. Maxwell's Alleged Offenses"

"it is clear from Congress' rejection of the retroactivity provision that it did not intend the 2003 Amendment to be retroactive"

"Application of the 2003 Amendment to Ms. Maxwell's Alleged Offenses Would Have Impermissible Effects."

"offenses with which Ms. Maxwell is charged. Neither enticement of an individual to travel nor transportation of a minor is an offense involving the se"

"Neither enticement of an individual to travel nor transportation of a minor is an offense involving the sexual or physical abuse or kidnapping of a ch"

"the government would prevail on the first Landgraf step. ... Ms. Maxwell's Motion should be granted for the separate and independent reason that regar"

"Attorneysfor Ghislaine Maxwell... /s/ Christian R. Everdell"

"Attorneysfor Ghislaine Maxwell... Jeffrey S. Pagliuca"

"Attorneysfor Ghislaine Maxwell... Laura A. Menninger"

"Attorneysfor Ghislaine Maxwell... Bobbi C. Stemheim"

"Ms. Maxwell respectfully requests that Counts One through Four be dismissed."

"Christian R. Everdell COHEN & GRESSER LLP"

"Jeffrey S. Pagliuca ... HADDON, MORGAN & FOREMAN P.C."

"Laura A. Menninger ... HADDON, MORGAN & FOREMAN P.C."

"Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim"

"18 U.S.C. § 2422(a) or 18 U.S.C. § 2423(a), the two Mann Act provisions with which Ms. Maxwell is charged"

"18 U.S.C. § 2423(a), the two Mann Act provisions with which Ms. Maxwell is charged"

"Ms. Maxwell's Motion should be granted for the separate and independent reason that regardless of whether the 2003 Amendment can be applied retroactiv"

"I served by email... the within memorandum... upon the following: U.S. Attorney's Office, SDNY"

"The government attempts to distinguish a long line of Supreme Court cases... none of the elements of either § 2422(a) or § 2423(a) constitutes sexual "

"the government's claim that it should prevail at step one can be easily dispensed with. ... Ms. Maxwell should prevail."

"the Second Circuit and First Circuit opinions in Weingarten"

"Senator Leahy, Amber Legislation, Cong. Rec. 149:50, S5147 (2003)"

"Senator Leahy, Amber Legislation, Cong. Rec. 149:50, 55147 (2003)"

"in the words of one of the bill's co-sponsors... Senator Leahy... the House-Senate conference agreed to drop language from the original House-passed b"

"the House version of the bill included an express retroactivity provision"

"the Senate version contained no retroactivity provision"

"proper application of Landgraf prohibits retroactive application of the 2003 Amendment"

"the government would prevail on the first Landgraf step. Rather, the second Landgraf step asks whether the effects of retroactive application of a sta"

"The Eighth Circuit's opinion in United States v. Coutentos, 651 F.3d 809 (8th Cir. 2011), squares perfectly with this approach. ... Similarly, § 3283 "

"it is alleged that the defendant [Vickers] did have sexual contact with Victim I"