court filing or legal brief: DOJ-OGR-00021863

The document argues that the PROTECT Act's amendment to 18 U.S.C. § 3283 applies to the defendant's pre-enactment conduct, as it plainly intends to prevent the application of any statute of limitations that would otherwise apply to past conduct. The amendment is deemed to be applicable to Maxwell's conduct as charged in the Indictment. The document cites relevant case law and statutory text to support its argument.