Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS COUNTS ONE THROUGH FOUR OF THE SUPERSED

OURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS COUNTS ONE THROUGH FOUR OF THE SUPERSEDING INDICTMENT AS TIME-BARRED Mark S. Cohen Christian R. Everdell COHEN &

31-7364 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00103709 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 SUMMARY OF ALLEGATIONS 2 ARGUMENT 3 I. The 2003 Amendment Does Not Apply Retr

. Step Two: Application of the 2003 Amendment to Ms. Maxwell's alleged offenses would have impermissible effe

inst retroactive legislation" that is "deeply rooted in our jurisprudence." Landgraf v. USI Film Prod., 511 U.S. 244, 265 (1994) (emphasis added). "Tillie principle that the legal effect of conduct should ordinarily be assessed under the law that existed when the conduct took place has timeless and un

n around since the Enlightenment (boosted by the Industrial Revolution). The names in this lineage include Descartes, Leibniz, Sadi Carnot, Clausius, Maxwell, and Watt. Wiener’s coinage nonetheless had profound cultural effects.4”7 The ubiquity today of the prefix “cyber-” confirms the desire for a crisp s

, performative, and postmodern, as in Lynn Hershman Leeson’s Dollie Clone Series (1995-98) consisting of the interactive assemblages CyberRoberta and Tillie, the Telerobotic Doll, who worked the technosphere with the professionalism of burlesque, winking and folding us viewers into an explicit consciousne

n around since the Enlightenment (boosted by the Industrial Revolution). The names in this lineage include Descartes, Leibniz, Sadi Carnot, Clausius, Maxwell, and Watt. Wiener’s coinage nonetheless had profound cultural effects.4”7 The ubiquity today of the prefix “cyber-” confirms the desire for a crisp s

, performative, and postmodern, as in Lynn Hershman Leeson’s Dollie Clone Series (1995-98) consisting of the interactive assemblages CyberRoberta and Tillie, the Telerobotic Doll, who worked the technosphere with the professionalism of burlesque, winking and folding us viewers into an explicit consciousne