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Case 22-1426, Document “Tatas | 3475900, Page150 of 208 | A146 | Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 9 of 34 I. The indictment is timely A. The indictment complies with the statute of limitations Federal law imposes a five-year limitations period for most non-capital offenses. 18 U.S.C. § 3282(a). Recognizing the difficulty of promptly prosecuting crimes against children, Congress has provided a longer limitations period for “offense[s] involving the sexual or physical abuse, or kidnaping” of a minor. 18 U.S.C. § 3283. Until 2003, the operative version of § 3283 allowed prosecution of these offenses until the victim reached the age of twenty-five. Congress further extended the limitations period in the PROTECT Act of 2003, Pub. L. No. 108- 21, 117 Stat. 650, to allow prosecution any time during the life of the victim. The parties agree that the Mann Act charges are timely if subject to the PROTECT Act, but untimely under the general statute of limitations for non-capital offenses or the pre-2003 version of § 3283. Maxwell contends that the charged offenses do not qualify as offenses involving the sexual or physical abuse or kidnapping of a minor and are thus governed by the general statute of limitations. Alternatively, she contends that the pre-2003 version of § 3283 applies because the charged conduct occurred prior to 2003. The Court concludes that statute of limitations in the PROTECT Act applies and that the charges are timely. 1. The Mann Act charges are offenses involving the sexual abuse of minors Maxwell does not dispute that the facts alleged in the S1 superseding indictment involve the sexual abuse of minors. The indictment charges that Epstein sexually abused each of the alleged minor victims and that Maxwell allegedly enticed them to travel or transported them for that purpose. Instead, Maxwell contends that charged offenses 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, DOJ-OGR- 00020768