Epstein Secrets

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

fices of Bobbi C. Stemheim Phone: Attorneys for Ghislaine Maxwell EFTA00028903 --- PAGE BREAK --- TABLE

etroactivity and Rejected a Proposal to Do So 3 1. Congress' explicit rejection of a retroactivity provision ends the inquiry at step one in Ms. Maxwell's favor. 3 2. Cases applying the 2003 Amendment retroactively are readily distinguishable. 5 3. The government cannot prevail at step one. 7

tivity provision ends the inquiry at step one in Ms. Maxwell's favor. 3 2. Cases applying the 2003 Amendmen

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,

20-cr-00330-AJN Document 207 Filed 04/16/21 Page 1 of 34 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC N: DATE FILED: 4/16/21 20-cr-330 (AJN) OPINION & ORDER ALISON J. NATHAN, District Ju

acts in violation of the Mann Act and two counts of conspiracy to commit those offenses. It also included two counts of perjury in connection with Maxwell's testimony in a civil deposition. Trial is set to begin on July 12, 2021. Maxwell filed twelve pretrial motions seeking to dismiss portions of the

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTR

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

20-cr-00330-AJN Document 207 Filed 04/16/21 Page 1 of 34 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC N: DATE FILED: 4/16/21 20-cr-330 (AJN) OPINION & ORDER ALISON J. NATHAN, District Ju

acts in violation of the Mann Act and two counts of conspiracy to commit those offenses. It also included two counts of perjury in connection with Maxwell's testimony in a civil deposition. Trial is set to begin on July 12, 2021. Maxwell filed twelve pretrial motions seeking to dismiss portions of the

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTR

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

20-cr-00330-AJN Document 208 Filed 04/16/21 Page 1 of 34 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 4/16/21 20-cr-330 (MN) OPINION & ORDER ALISON J. NATHAN, District Jud

acts in violation of the Mann Act and two counts of conspiracy to commit those offenses. It also included two counts of perjury in connection with Maxwell's testimony in a civil deposition. Trial is set to begin on July 12, 2021. Maxwell filed twelve pretrial motions seeking to dismiss portions of the

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTR

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