Epstein Secrets

the Sexual or Physical Abuse or Kidnapping of a Child 14 CONCLUSION 16 EFTA00028904 --- PAGE BREAK --- TABLE OF AUTHORITIES Page(s) Cases Bridges v. United States, 346 U.S. 209 (1953) 11, 13, 14 Burrage v. United States, 571 U.S. 204 (2014) 14 Cisneros v. Alpine Ridge Group, 508 U.S. 1

WL 2351484 (D. Conn. June 7, 2010) 5 United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 1838255 (W.D.N.Y. May 8, 2014) 15 Vernon v. Cassadaga Valley Cent. School Dist., 49 F.3d 886 (2d Cir. 1995) 9 iii EFTA00028906 --- PAGE BREAK --- Weingarten v. United States, 865 F.3d 48 (2d Cir. 2017) 5, 6,

elements of § 2422(a) and § 2423(a), and to disregard allegations of conduct beyond those elements. Finally, the government attempts to distinguish Bridges, in which the Supreme Court used the equivalent of a "necessarily entails" approach specifically with respect to a statute of limitations, and argu

do not qualify as offenses involving the sexual abuse of minors because sexual abuse is not an essential ingredient of each statutory offense. See Bridges v. United States, 346 U.S. 209, 221 (1953). In Maxwell's view, 9 EFTA00020269 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 207 Filed 04/16

eptance Co., LLC, Sec. Litig., 391 F.3d at 407. Applying it to conduct for which the statute of limitations has not yet expired does not. Vernon v. Cassadaga Valley Cent. Sch. Dist., 49 F.3d 886, 890 (2d Cir. 1995). Maxwell concedes that these offenses were within the statute of limitations when Congress enacted the

do not qualify as offenses involving the sexual abuse of minors because sexual abuse is not an essential ingredient of each statutory offense. See Bridges v. United States, 346 U.S. 209, 221 (1953). In Maxwell's view, 9 EFTA00022099 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 207 Filed 04/16

eptance Co., LLC, Sec. Litig., 391 F.3d at 407. Applying it to conduct for which the statute of limitations has not yet expired does not. Vernon v. Cassadaga Valley Cent. Sch. Dist., 49 F.3d 886, 890 (2d Cir. 1995). Maxwell concedes that these offenses were within the statute of limitations when Congress enacted the

do not qualify as offenses involving the sexual abuse of minors because sexual abuse is not an essential ingredient of each statutory offense. See Bridges v. United States, 346 U.S. 209, 221 (1953). In Maxwell's view, 9 EFTA00029548 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 208 Filed 04/16

eptance Co., LLC, Sec. Litig., 391 F.3d at 407. Applying it to conduct for which the statute of limitations has not yet expired does not. Vernon v. Cassadaga Valley Cent. Sch. Dist., 49 F.3d 886, 890 (2d Cir. 1995). Maxwell concedes that these offenses were within the statute of limitations when Congress enacted the