DOJ-OGR-00005187.pdf

--- Page 1 --- **Document Header:** * **Case Number:** 1:20-cr-00330-PAE * **Document Number:** 338 * **Filed Date:** 10/12/21 * **Page Number:** 9 of 22 **Handwritten Notes:** * when congress corrected this as a "technical correction" I conforming repeal in 1994 they knowingly did not include or reference the Child Abuse definitions at 35 U.S.C. § 3509(a)(3)-(a)(9), (11), which appear to be for tort law, and are clearly incompatible with the Child definition at 35 U.S.C. § 3509(a)(2). These civil definitions are for Reporting of abuse. See 18 U.S.C. § 2258 which references them from Title 42. * see Ibrania v. Holder, 1736 F.3d 902, 910 (10th Cir. 2013) ( Civil and Criminal definitions frequently differ). "Courts do not lightly assume that congress has omitted from its adopted text requirements that it none the less intends to apply." Jama v. Immigration & Customs Enforcement, 543 U.S. 335, 341 (2005). After one technical correction and two later amendments congress knew what it was doing by not including or referencing the 35 U.S.C. definitions from § 3253. Furthermore, the limitation was misplaced. "Proper statutory construction requires considering a phrases placement and purpose in the statutory scheme.... The meaning of statutory language plain or not depends on context." Brown v. Gardner, 513 U.S. 115, 118 (1994) * I, see 35 U.S.C. § 3509(a)(10) sex crime definition **Footer:** * **DOJ-OGR-00005187**